What happened?
TCC and Recordsure recently hosted an industry webinar: ‘Driving change – FCA redress and the future of motor finance’, featuring CCO Garry Evans, Advisory Director Gary Maude, and Momenta Head of Operations Mike Morris. The panel explored the massive operational challenge created by the Supreme Court’s Johnson ruling and the FCA’s proposed redress scheme.
The discussion highlighted critical challenges, including handling CMC-driven complaints, resourcing massive remediation spikes, and deploying advanced technology to scale calculation and communication workflows.
Why does it matter?
The Supreme Court’s Johnson ruling has narrowed the legal definition of commission fairness while complicating its operational application. While commission size, disclosure transparency, and consumer vulnerability dictate fairness, firms must assess cases individually rather than applying blanket rules.
This individual assessment, coupled with a surge in claims management company (CMC) complaints, creates a major resourcing crisis. Lenders face a severe shortage of skilled complaints-handling personnel, making automated, tech-led workflows critical to process claims on time.
Supporting sources
Frequently asked questions
What was the significance of the Supreme Court's Johnson ruling?
The ruling established that the fairness of commission arrangements depends on specific case factors like commission size, disclosure quality, and customer characteristics, requiring case-by-case reviews.
Why is resourcing a critical challenge for motor finance firms?
The expected surge in commission complaints will trigger an acute industry-wide shortage of specialist complaints-handling staff, driving up costs and causing severe processing delays.
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- Lending & Consumer CreditTCC helps consumer credit firms evidence good outcomes, strengthen affordability and vulnerability frameworks, and manage complaints, remediation and regulatory risk. We support lenders with practical, regulator-ready compliance programmes that improve governance, customer treatment and operational resilience.
- Motor FinanceTCC helps motor finance lenders, brokers and providers assess redress exposure, prepare for large-scale customer reviews and strengthen complaints, affordability and Consumer Duty frameworks. We combine regulatory advisory, managed operations, specialist resource and technology-enabled assurance to deliver consistent customer outcomes, robust governance and regulator-ready evidence under heightened FCA scrutiny.