FCA guidance on multiple representation in motor finance complaints

The FCA and SRA have issued joint instructions on managing multiple representatives representing a single motor finance complainant, requiring lenders to execute strict due diligence.

What happened?

The Financial Conduct Authority (FCA) and the Solicitors Regulation Authority (SRA) have issued a joint message addressing multiple representation in motor finance commission claims. The regulators highlighted instances where up to four representatives were instructed on a single claim.

To support lenders, the FCA has released a Dear CEO letter detailing required administrative and communication steps to resolve these duplicate claims and prevent consumer confusion.

Why does it matter?

Multiple representation delays claims processing, increases costs, and can result in unexpected customer termination fees. As firms prepare for the lifting of the motor finance complaint pause on 31 May 2026 and the finalisation of the Consumer Redress Scheme, managing these duplicates is critical.

Lenders are expected to perform robust due diligence to identify multiple representations and constructively engage with all parties to determine a single, authorized representative.

Who is affected?

Motor finance lenders, claims management companies, law firms and customers involved in motor finance commission complaints. It is particularly relevant where more than one representative has been instructed to act on the same customer complaint, creating additional complexity for complaints handling and redress processes.

Key risks

  • Multiple representatives acting on the same complaint, creating confusion around who is authorised to act.
  • Delays to complaint resolution and implementation of the Consumer Redress Scheme (CRS).
  • Poor customer outcomes due to unclear communication and duplicated activity.
  • Customers potentially incurring unnecessary termination fees when switching representatives.
  • Increased regulatory scrutiny if complaints-handling, governance and remediation frameworks do not meet FCA expectations.

Actions to take

  1. Identify complaints involving multiple representatives.
  2. Confirm who the sole authorised representative is and keep the customer informed.
  3. Close duplicate complaints once a sole representative has been identified.
  4. Review complaints-handling and governance processes ahead of the Consumer Redress Scheme.
  5. Ensure readiness for increased regulatory scrutiny and complaint volumes.

Supporting sources

  1. FCA guidance on multiple representation in motor finance complaints

Frequently asked questions

What is multiple representation in motor finance claims?

It is when a complainant has instructed multiple claims management companies or law firms to represent them on the same commission claim.

What are lenders expected to do when duplicates are found?

Lenders must contact all representatives and the customer, assist in identifying a sole authorized representative, and then close all duplicate files.

Reviewed by TCC Group Editorial Team

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