Second motor finance CMC probe signals a harder line on claims conduct

The FCA has opened an enforcement investigation into Consultation Claims Limited (CCL) over its conduct between April 2025 and December 2025, including allegations that consumers were signed up without consent and that signatures were forged (FCA). It is the second such investigation into a motor finance claims management company, and the regulator has chosen to name CCL publicly on the basis that the "exceptional circumstances test" in its enforcement guide has been met (FCA).

The procedural detail matters as much as the allegation. CCL agreed a Voluntary Requirement with the FCA running from 8 December 2025 to 2 March 2026, under which it stopped taking on new customers and wrote to existing ones offering free cancellation (FCA). The VREQ was lifted once CCL met the regulator's conditions, yet the enforcement investigation has still been announced — and announced publicly. That sequence tells boards something important: cooperation with supervisory tools no longer buys quiet treatment when the FCA judges that consumer confidence is at stake. Firms that assumed a VREQ marked the end of the story will need to revise that assumption.

The pipeline pressure on lenders

The scale of the surrounding intervention is becoming material. The FCA has removed or amended over 1,000 misleading motor finance adverts, more than 28,000 consumers have exited CMC contracts free of charge, and a joint taskforce with the SRA, ICO and ASA was announced on 30 March 2026, followed by a review of the claims management market launched on 6 May 2026 (FCA). For motor finance lenders, this changes the composition of the redress queue. A meaningful share of claims sitting in complaints pipelines may have been generated by CMCs whose customer onboarding is itself under investigation. That has direct implications for evidence weighting, complaint validity tests, and the assumptions underpinning provisioning models.

Senior leaders at banks and captive lenders should also read the regulatory signalling more broadly. The FCA's willingness to name a firm mid-investigation, in a sector adjacent to but distinct from the lenders themselves, is consistent with the gatekeeper-tightening posture seen across financial promotions and Section 21 approvers. The same logic — that consumer protection outranks the firm's interest in confidentiality — will travel. Boards of authorised firms with any claims-handling, introducer or third-party intermediary exposure should expect that supervisory engagement now carries a higher probability of public disclosure than it did twelve months ago.

What boards should be doing now

Three actions follow. First, lenders should map their motor finance complaint inflow by originating CMC and stress-test what happens if a material proportion of submissions are later found to have consent or signature defects — both for redress liability and for the integrity of any past business review. Second, compliance functions should revisit the firm's own VREQ playbook on the assumption that voluntary undertakings will not insulate against subsequent enforcement announcements. Third, communications and investor relations teams need a position ready for the moment a counterparty CMC is named: silence will be read as proximity.

The FCA has not concluded that CCL breached any requirements (FCA). That caveat is doing less work than it used to. The regulator is using disclosure as a supervisory instrument, and the motor finance complex — lenders, CMCs, law firms and their boards — is the test bed.