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The increased attention on firms’ historic motor finance Discretionary Commission Arrangements (DCA) presents a range of conduct and prudential challenges for firms. We can provide solutions to all of these challenges, including advice and representation, systems and controls implementation, and executing policies and procedures as to:

• Responses to customer enquiries
• Handling complaints and any applicable redress or operational process changes
• Record-keeping; and
• Maintaining and deploying financial (insurance and other capital) resources. 

Why choose us

Our specialist team has a wealth of experience in the effective handling of financial services complaints which have the potential to cause significant disruption to businesses, whether from their individual attributes (such as value or complexity) or their aggregate volume. Our complaints response experience includes credit broking and lending, and associated financial services products (including PPI, interest rate hedging, business interruption insurance), in motor and other consumer goods and services industries.

Our lawyers have worked on matters involving the key legal factors arising out of consumer credit claims and complaints, such as from the cases of Plevin and Hurstanger. Our team includes a former Financial Ombudsman, Lisa Wright, who can provide extensive insights into FOS’ approach – in particular in relation to allegations of ‘secret commissions’ and fiduciary duties.

Our services

Services we can provide on a discrete or combined basis, working alongside clients’ existing compliance, governance, legal and risk functions, include:

• Customer-facing communications tailored to each phase of the FCA review ensuring your customers stay informed on key milestones and receive prompt, individualised complaint responses which can be delivered at scale. 
• Document management processes to create a clear and comprehensive understanding of any commission arrangements which may have been implemented. 
• Evidential, contextual and statistical analysis to support complaint outcomes and regulatory responses that are reflective of identified commission arrangements. 
• Developing a framework to ensure individual complaints are answered appropriately and effectively whilst ensuring consistency of complaint outcomes.
• Creating a complaints platform, using existing technology, custom designed with your customers, systems and processes in mind to assist in the triaging of DCA and any other motor finance complaints.
• A dedicated helpline and a tailored email address to give you easy access to our expert complaints-handling team.