FCA motor finance commission redress scheme support

End-to-end support tailored to your business

The FCA’s proposed motor finance redress scheme is likely to require significant operational, data and governance reviews by lenders. Gateley Legal supports clients to design and deliver a compliant, transparent and auditable redress approach – from scheme interpretation through to calculation delivery and assurance.

Why motor finance redress is complex

  • Loss-based APR adjustment can require recalculating schedules (or actual payments) under a lower APR and deriving redress from differences in payments.
  • The scheme is hybrid, combining APR adjustment with a simpler rebate-style calculation in certain scenarios.
  • Complexity increases where loans deviate from the contractual schedule (e.g., partial settlements), driving the need for a granular, flexible and auditable calculation solution.

How Gateley Legal can help

  • Scheme interpretation and legal advice: We can translate rules into a practical, defensible approach.
  • Staff: Our expert team can provide immediate resource to assist with backlogs, customer queries and data reviews.
  • Programme governance: We provide controls, decision logs, documentation standards and reporting.
  • Data readiness: All data requirements, including validation checks and remediation for gaps and inconsistencies will be carried out.
  • Calculation design and delivery: We deliver scalable solutions, aligned to scheme rules and portfolio features.
  • Assurance: We carry out an independent review of methodology, documentation and code; sampling and edge-case testing.
  • Outputs, MI and evidence: We support on Cohort MI, exception handling and audit-ready packs for scrutiny.

A practical engagement approach

  • Mobilise: Confirm scope, governance and documentation standards.
  • Discover and prepare: Review interpretation, portfolio features and data readiness.
  • Build and test: Develop/ configure the calculation solution and test edge cases.
  • Run, report and assure: Process cohorts, handle exceptions, deliver MI/ evidence and provide assurance support.

Finding the approach that works for you

We provide two options, designed for you to pick your core plan and add elements of the other for independent challenge and assurance.

1. Calculation development and deployment 2. Calculation review and assurance
  • Operate calculations on your behalf (or alongside your internal build).
  • Flexible, scalable calculation engine tailored to your data and system constraints.
  • Transparent edge-case review using a single-loan calculator.
  • Reporting with full audit trail and data quality checks.
  • Independent assessment of your proposed calculation approach and documentation.
  • Targeted review of methodology and code, including sampling and edge-case testing.
  • Optional independent re-processing for comparison, with findings and priority recommendations.

 

Our calculation approach

Our delivery is structured around three transparent models.

1. Data

  • Define data requirements and mapping to scheme logic.
  • Validation checks to identify gaps, inconsistencies and unknown codes.

2. Calculation engine

  • Scalable redress calculation engine with clear version control.
  • Flexible framework for scheme updates and portfolio-specific features.

3. Outputs and audit trail

  • Account-level results with evidence summaries (inputs, logic and outputs).
  • Cohort-level MI and exception reporting, with error logs and decision documentation.

Our delivery model

1. Advise

  • Best practice input and challenge to guide your programme and governance.

2. Assurance

  • Independent review of methodology, documentation and code; staff provided to reduce your load

3. Design

  • Pragmatic solutions including methodology, controls and MI.

4. Execute

  • Specialist capability to build, test and run calculations at scale.

Get in touch

We support clients to design and deliver a compliant, transparent and auditable redress approach – from scheme interpretation through to calculation delivery and assurance. Get in touch with our expert team to arrange an initial scoping session and obtain a short proposal tailored to your portfolio and operating model.

Got a question?

Speak to our financial regulation team