Second motor finance CMC probe signals a harder line on claims conduct
The FCA has opened an enforcement investigation into Consultation Claims Limited over allegations including forged signatures on motor finance claims, the second such case and part of a widening crackdown on the CMC sector. For lenders, redress providers and their boards, the regulator's appetite for naming firms under investigation rewrites the reputational calculus around the motor finance remediation pipeline.
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.
What this reveals
The FCA's decision to publicly name a firm mid-investigation, even after it had cooperated through a Voluntary Requirement, signals that the reputational calculus around supervisory engagement has shifted. Boards that assumed cooperation buys confidentiality, or that CMC conduct is someone else's problem, are working from an outdated model of how the regulator now weighs consumer protection against firm interest. For lenders, the more consequential exposure is that their redress pipelines may be populated by claims from CMCs whose onboarding evidence is itself contaminated, meaning provisioning assumptions and complaint-handling logic built on the integrity of that intake are now suspect. The broader pattern, visible across Section 21 approvers and financial promotions, is that any firm relying on third-party intermediaries should assume gatekeeper-style scrutiny will travel to them.
Questions accountable leaders should ask
- 01What proportion of complaints in our motor finance redress pipeline originated from CMCs, and do we know which of those CMCs are subject to supervisory intervention or investigation?
- 02If a regulator named us publicly during a live investigation, would our current stakeholder communications plan, board reporting cadence and provisioning disclosures hold together, or were they built on the assumption of confidentiality?
- 03How are we testing the authenticity of consumer authority and complaint validity from third-party introducers, and would that testing survive challenge if the intake evidence turned out to be forged or unconsented?
- 04Where else in our business do we rely on third-party intermediaries, introducers or approved persons whose conduct we do not directly supervise, and what would a gatekeeper-tightening posture from the FCA mean for those relationships?
- 05Do our provisioning models and redress assumptions distinguish between claims backed by verifiable consumer authority and those which are not, or do they treat the pipeline as uniformly valid?
What accountable leaders should do now
- 1Commission an immediate stock-take of the redress pipeline segmented by CMC of origin, flagging exposure to firms subject to VREQs, investigation or enforcement, and quantify the share of claims whose intake evidence may not withstand scrutiny.
- 2Revisit provisioning and complaint-validity assumptions with the audit committee, making explicit where the model presumes CMC intake integrity and where that presumption is now unsafe.
- 3Stress-test the firm's own third-party and introducer arrangements against the gatekeeper posture the FCA is signalling, and identify any relationships where onboarding, authority or promotional conduct would not survive equivalent scrutiny.
- 4Update the board's reputational and disclosure playbook on the working assumption that supervisory engagement, including cooperative tools like VREQs, may become public, and rehearse the communications sequence accordingly.
- 5Establish a standing signal-monitoring routine on FCA enforcement conduct and public-naming decisions so the board is reading the direction of travel in real time, not after the next escalation.
Explore the practical guide
This guide sets out how senior leaders at FCA regulated firms should identify, assess and manage stakeholder risk in a way that stands up to supervisory scrutiny. After reading, you will know how to structure a stakeholder risk framework that connects to Consumer Duty, SM&CR accountability and board-level reporting.
Read the guideWhere internal confidence may exceed external evidence
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