Navigating FCA attestation in the Motor Finance Redress Scheme: A roadmap to readiness

In our previous article, we explored the Financial Conduct Authority’s proposed redress scheme addressing the Motor Finance Commission issue. We outlined the key components of the proposed redress scheme, including the critical requirement for attestations from the designated Senior Manager (SMF) responsible for overseeing and delivering the programme.

The FCA has made it clear that firms failing to comply with the prescribed procedures of the Motor Finance Redress Scheme will face regulatory consequences. To enforce compliance, the FCA has a range of supervisory and enforcement tools at its disposal. These may include the appointment of a skilled person, financial penalties, and other regulatory interventions. In particular, the SMF appointed to oversee the scheme carries specific responsibilities and may be held personally accountable if those obligations are not met.

A framework for gaining confidence over Redress Scheme compliance

Ahead of the FCA’s final publication of the Motor Finance Redress Scheme, firms are encouraged to undertake preparatory reviews to assess their operational readiness and identify areas requiring early attention. These reviews typically focus on governance structures, resource planning, data integrity, and customer communication strategies to ensure alignment with regulatory expectations.

Key areas of consideration include:

• Evaluating programme oversight.
• Verifying the completeness and accuracy of customer data.
• Assessing the robustness of fraud prevention controls.

For example, firms may review how responsibilities are allocated across teams, whether customer records are traceable to original agreements, and whether safeguards are in place to detect duplicate or suspicious redress claims. Firms may also review their approach to customer segmentation and redress calculation frameworks, ensuring these are designed to support fair outcomes once the scheme is finalised, such as correctly identifying in-scope customers and applying consistent logic across varied contract scenarios.

Following the FCA’s publication, attention will shift to validating execution and maintaining compliance throughout the redress process. This includes confirming the accuracy of redress calculations across different customer types, monitoring how customer queries and disputes are handled, and validating that settlement payments are made correctly and on time. Firms should also ensure that reports submitted to the FCA reflect complete and reliable data and conduct periodic spot checks to identify any emerging risks, such as anomalies introduced by system updates or changes in operational procedures.

By taking proactive steps now, firms can build confidence in their ability to meet the FCA’s requirements and deliver a redress programme that is both compliant and customer-focused.

Get in touch

Our deep expertise in the Motor Finance space enables us to support firms across the industry with confidence and precision. We’ve developed a robust framework to help firms meet the compliance requirements of the FCA’s proposed redress scheme, while equipping the appointed SMF with the assurance needed to fulfil their attestation responsibilities.

We recognise the complexity and sensitivity of these matters and offer a comprehensive suite of services tailored to each firm’s unique circumstances and stage in the redress journey.