Mastering Motor Finance Redress: Hard-won lessons learned from PPI

Samad Masood:

Welcome, good afternoon and thank you all for joining this exclusive webinar. As many of you already know, the British motor finance industry could be facing tens of billions in new costs, all relating to how commission payments have been charged historically. In particular, the Supreme Court is about to rule on the legality of non-discretionary commissions and its decision could kick off a chain of events that lead to payouts similar in scale to PPI compensation payments of the past. Thankfully, with me today are three panelists that are highly experienced in the compliance, operational, and technical aspects of effective financial redress. And they're here to help us understand how motor finance firms can master the operational and regulatory changes coming their way in the next few months. First, let me introduce Natalie Gjertsen, Risk and Compliance Leader for EMEA at Infosys Consulting, and with her, Sha Ali, an Associate Partner for Risk and Compliance at Infosys Consulting. And joining us, we also have Kate Robinson, Principal at Avyse Partners. Welcome to you all.

Natalie Gjertsen:

Thanks a lot.

Kate Robinson: Sha Ali:

Thanks, good to be here.

Sha Ali:

Thank you.

Samad Masood:

So let's kick off with you, Natalie. Can I ask you to help us untangle the quite complicated sequence of events that are happening here from the Supreme Court and the FCA is involved as well? What can we expect and what's the process?

Natalie Gjertsen:

Sure, thanks Samad. So we believe that the Supreme Court ruling is due to happen later this month. Following that, the FCA have said that if they conclude that the modes of finance consumer has lost out, then they would likely consult on an industry-wide consumer redress scheme, where they would set out rules for how firms assess the claims and also calculate redress. Given that they've already been engaging with stakeholders, it is possible that the FCA will decide to have a shorter consultation window. They've moved to the point of potentially six weeks. And this will enable them to then give clear requirements and guidance to set out so that we can commence any form of redress.

Samad Masood:

Great, thanks. Kate, what do you think the Supreme Court is going to conclude? And I'm asking you to do a bit of future gazing here, but what do you think is likely to come out of the court?

Kate Robinson:

Yeah, I think it's difficult. I don't have a crystal ball, but I think at the moment, the mood music is very much around that the Supreme Court will find in favor of the lenders. So just for a bit of context, previous judicial decisions have found in favor of the customer. And so as it stands, the legal landscape for when it comes to the disclosure of commission and there’s two different types of disclosure. There is fully secret and half secret commission, both found in favor of the customer, that the customer was put in a position where they may have made a different decision and ultimately lost out as a result of that type of commission disclosure. There are four questions that the Supreme Court is considering. Bets are on a decision middle of next week in terms of the outcome. I'm sure they will lay out that outcome really clearly in their paper however I think most people are hoping that it will be in the lender's favour. That said we've been told not to count our chickens before so it could be interesting. I wouldn't like to nail my colours to either mast at the moment if I'm honest.

Samad Masood:

Thank you. A good bit of crystal ball gazing there, nonetheless. And you think really that there's that feeling that the tide is maybe turning towards the landers, but we'll see hopefully sometime next week. There is the consultation though, Natalie, and how long do you think that could take? Could we see it take us to the end of the year or will it happen quite quickly, do you think?

Natalie Gjertsen:

Sure, so if they do announce next week, the FCA have then said that they'll respond or have some form of announcement within about six weeks. So that will take us to say early to mid-September. If they choose to have a shorter consultation period, then that window should probably close end of October-ish. So therefore, I think we could expect an announcement from the FCA towards the back end of this year on how firms will need to move forward in regards to any form of redress in this space.

Samad Masood:

So it's something we need to prepare for now, I suppose, and be ready for regardless. Kate, back to you. What do you think the FCA's direction will be? You know, again, I'm asking you to do all of the future gazing here. But what do you think might come out of that process?

Kate Robinson:

So I think we need to think about what the FCA have to decide. So we've got two issues really here. We've got one issue that they've already concluded on, which is the discretionary commission arrangements. They have in 2021 banned that type of arrangement. They found harm and loss to a customer in relation to that arrangement. I think if there is going to be any scheme, it's very clear that that will definitely be within the scheme. So the DCA model and that model is whereby effectively the broker was able to influence the interest rate the customer paid as a result of the type of commission arrangement that they had with the lender. So I think that that's clearly part of the scheme. So I think that that's clearly part of the scheme. I think then what they're waiting on is this decision from the courts to understand how or if the scheme should be expanded. And that comes and looks at the type of commission disclosure, whether the customer was aware that a commission was being paid from the lender to the broker, and whether that was a fully secret commission or whether it was a part disclosure. So that's kind of their first part of consideration. They'll also be looking at from a scheme point of view, the extent to which firms should work on what's called an opt-in or an opt-out basis. My view is that they will always go on the basis that firms should identify all customers potentially affected and it will be the firm's responsibility to make that identification as opposed to the customers to flag it. Reasons for that, I think it may hopefully reduce the number of CMCs who are trying to act in this space on behalf of customers. And I know that that's one thing that the regulator has been quite clear on, that ultimately the customer should be able to make a claim for compensation by themselves without the help of a third party CMC, particularly in this space. So there's that opt in versus opt out. There's the size of the scheme.

There's also the timing. And as Natalie mentioned, I think once that decision has been made by the courts, FCA have done a huge information grab from firms recently. They are well placed to make a decision on that shape and scale of team over the next few weeks. And I think that's what will happen in the next six weeks. So from the point of decision from the court, there will then be a decision within the next six weeks from the regulator in terms of the size and shape of the scheme and the opt-in versus opt-out options. Once that has been communicated to firms, there then needs to be a period of consultation. But given the amount of work and how long this issue has been going on for, I do think that consultation, they're looking to reduce it from the usual three months. So, all working, my best guess is that Redress will be mobilized from January 2026.

Samad Masood:

Great. So it sounds like some lessons have been taken or you expect some lessons to have been taken by the regulators around, you know, in the previous PPI repayments and maybe perhaps trying to manage that a bit more sensibly, dare I say.

Natalie Gjertsen:

For many firms, this will be a very large program of activity. It's significant, as Kate said, having to potentially go back and look at all of your customers that are impacted, communicate out to them, undertake the case analysis and do the payment. It is going to be a big amount of work and detailed planning will be required for a smooth execution. It'll also cost high, a lot to execute. There'll be people involvement, technology involvement, and even the redress payments. So the cost of this program will be significant. And also, there'll be a significant impact on senior management and leadership reporting up to the board. Reporting will be important. The board will want to understand what is happening. And also, you'll need senior stakeholders to make decisions. And also, I think the other big impact will be potentially ongoing regulatory reporting. So as Kate mentioned, the FCA has already been engaging with a lot of organisations, understanding the data, the scale of the issue, I suspect that that regulatory interaction will continue and that will be a time consuming effort for firms that they need to consider when preparing for this programme.

Kate Robinson:

I think Natalie's absolutely right. Firms shouldn't underestimate the amount of work that is required for a redress exercise. What I would say is that that work shouldn't start at the point at which FCA announced their direction of travel. You've got a real opportunity firms in the here and now to influence that direction of travel. So given the huge amount of information that firms have already had to present to FCA, they should be in a really good position to clearly engage now to help shape the scheme. So not only at the point of consultation, but at the point of now helping FCA to understand the differences and any constraints around, for example, opt in versus opt out, the shape and the scope of the scheme in terms of a firm's future resilience. I do think we'll make a difference to the size and scale of any 404 redress that comes forward.

Samad Masood:

So, Sha, I wanted to come to you with regard to technology and data. So you've spent many years building platforms to process PPI payments. So tell us a bit about the challenges and lessons learned you had from that and, you know, what do you think in terms of new technology companies should be leveraging now that things have moved on quite a bit since then?

Sha Ali:

Yeah, thank you. I guess before I start, I just want to quickly contextualize PPI, the lessons learned from PPI. PPI was probably the largest kind of remediation in FS banking history up until that point. So it was big, it was large, and it was really hard. So everybody learned some lessons and I certainly learned some lessons, okay. But there are other remediations like KYC and PAC and CRS and tris rate derivatives that I've been involved in. And there are some common themes and I just wanted to bring those forward from kind of a lessons learned perspective.

Now, the data within PPI was sometimes 20 years old or more. The data within multi-finance redress is going to be in some cases 18 years old, but certainly it's going to be old. So I want to start kind of the first lesson learned was talking about data. So, we have an opportunity now before the scheme starts to really look at sourcing the data, grabbing the data, cleaning it, making sure it's right, making it consistent, because obviously systems have changed over time. So there's a lot of preparatory work to be done.

Just picking up on the age thing around the data. People would have moved address, people would have changed names because they got married or just changed their names or whatever. So a lot of data will be out of date. So third party data sourcing is going to be really a critical part of it. So we start with the data, getting that right and making sure you have a really solid data platform before you move on to anything more. Because you don't want to be fixing the data as you go. Of course, there'll be a little bit of that, but you want to limit that as far as you can. I'd always start with the data. And certainly that was a big lesson learned in PPI. During the PPI remediation that I've worked on, something like 20% of the customers changed their details during the course of that remediation.

So we're going to get old data plus changes of data will really take care of those. So aside from the data, I think there are some common themes as well from all of the remediations that I've worked on. And that's sort of five key technology elements I wanted to talk about. And I'll just be very brief.

Of course, the data fabric, so I'm not going to talk too much about that because I just talked about data. But the next, and I think probably the most important thing you have to get right is implementing a workflow platform. I saw many people in remediation, whether that's PPI or other, not implement workflow. And they really struggled because you can't understand where the bottlenecks are. You don't know what the statuses are. It’s very difficult to report. And also, it's very difficult to access additional automations without that workflow stitching together the process. So workflow really important to implement. So that's the second one after the data.

Now, within the process, all remediation, PPI and multi-finance as well require a lot of documentation. Multi-finance got, you know, finance, the finance documents, they've got other documents that needed to be signed, that needs to be gathered and stored against the case. But you'd also collect lots of documents as you go. So identity documents, change of address documents, et cetera, and storing them in a single document storage application is really critical.

So if you don't have one, now is the time to invest in one because you get benefit from it now and also in the future. If we assume there are going to be lots of documents involved, and we can, I think, safely assume that, then you're going to have to really implement a document intelligence platform where you can extract data out of those documents. And in PPI, we had that. And in other remediations, we also had that. But with AI now, the document intelligence is absolutely phenomenal, where you can act on the data within documents. You can extract data within documents and reason on it with other structured data elements. So document intelligence investing in that is going to probably pay for itself, I think, to a certainty.

And the final sort of historical component is having a really good communications hub. So if you think about the process, you have to potentially write out to the customer. They're going to write into you. You may get emails, letters, SMS, you know, chat potentially given the modern age that we live in. All of those communications need to be unified in a single place and not interleave in a poor way. So you get like duplicate communications or too much or too little communication. So having that communication hub and integrating it with the workflow, as I mentioned earlier, you need that workflow to stitch together all of the automation is really important. So those are the kind of five elements.

And then just bringing us up to speed. Everybody's talking about AI and everybody would use sort of generative AI as part of process. But I think where we could really benefit in this time for multi-finance is really in the agentic AI space. So taking those cases, reasoning on the cases, understanding what to do, and then doing the next best action, either with approval from a human or on a risk-based approach if the redress amount is low enough to actually just allow the AI to just offer the redress and accept and then move forward.

I want to just very briefly, if I can, just mention two other very quick points that are not part of the tech stack, okay? And Natalie touched on this. From a tech perspective, you need to assume everything's gonna change. So rather than as a design ethos that you need to go in with, which is, think that everything is going to change so that you can be very flexible in the architecture. There's lots of design techniques that can allow you to do that. But just building static workflow or building things that are difficult to change, you're going to get yourself into a model very, very quickly.

And then the final point, just to wrap up, is having done lots of remediations, the tech team are pushed incredibly hard. And this is not a plea to go easy on the tech team at all, but it is a very stressful delivery because it's under regulatory pressure and there's lots of things to do. But pushing a tech team too hard leads to poor quality. That leads to issues around quality, which you then have to deal with later operationally. I would say be a bit careful about that.

Natalie Gjertsen:

And just anchoring on Sha's last point there, keeping an eye on people, I would also agree that across your entire programme, these are really hard, difficult programmes. It's really important you look after your team and make sure that they're fully supported and with the right level of resource in order to be able to deliver for you. Because these programmes won't be short. I suspect they will go into the beyond 12 month period, particularly for some of the big organizations with a big exposure. So looking after them is critical.

Some of the other key things to think about with regards to operations, one is around the importance of undertaking a pilot. So test that process end to end ahead of go live. Make sure that cases can flow through from one end to the other. If there are issues that are identified in that pilot, work on them, fix them ahead of going live. And also, something I said earlier, have a process improvement team ready to go and pick up those issues. So you've got continuous improvement when you're running, but also that pilot going into live, it's really important you fix those issues.

Sha Ali:

I would also say, Natalie, that with regard to the pilot, making sure that the operations don't go off system too much is really important. Otherwise, you have kind of a process that is orchestrated by technology, and then you have several offline spreadsheets, and then we sort of try to get into a bit of a model there as well. So that pilot really helps to prevent those offline systems because you're piloting those small offline spreadsheets or whatever trackers while the core technology is being built. So I wholeheartedly agree with the pilot comment that you just made.

Kate Robinson:

Yeah, I'd add just one last bit to that pilot piece from the final angle of the reg compliance piece. With a pilot, it's really nice audit trail that you have demonstrated that you have taken appropriate steps to get to the right customer outcome. And customer outcomes and good customer outcomes is ultimately what any redress scheme would be looking to deliver. So the more you can demonstrate that test, challenge, and learn approach, the less likely there would be any form of later intervention, like there were for some firms in PPI where they had to go right back to the beginning and have to kind of remap and do everything again, which is something we don't want to do.

Natalie Gjertsen:

So just on that point, Kate, just going back to it, I guess that point around record keeping from the start as well. As you mentioned around the pilot, but also be starting to think now of what your post-program closed down work needs to be. What do you need to prepare for? Will an internal audit review happen? Will an external regulatory review happen? So, you know, making sure that you've got strong records and a system of record, particularly on decision making, because none of us will remember those very, very kind of minute but significant decisions that were made upfront. If we don't, you know, make sure that we write them down and we can refer back to that documentation at the end. So record keeping is critical. Yeah. Very critical.

So resources—we need to consider the location of our operational teams. Onshore resources can drive really high costs. So we want to try and minimize onshore resources if possible. So using offshore teams, whether they're in-house or engaging with a third party, can offer you a reduced operational cost potentially. And also we need to be prepared to scale that operational support as well. So don't assume that you'll be able to get skilled resources magically because this is a really significant issue impacting many firms. And I suspect the contracting pool may be limited, which is what we saw previously with other remediations. So it is back to our original point: it's really important to plan ahead of time, model what you think you're going to need, and start to talk to providers or your internal teams offshore and start preparing them for any training or upskilling that will be required in order to deliver the cases.

Kate Robinson:

And just to give that angle as well, I think, you know, ultimately all firms who are captured by this issue are also required to meet the principles and rules of consumer duty, the purpose of which is to avoid foreseeable harm. This is an issue where you can see harm coming down the line. And therefore, if there is any question on resources later on, I think the FCA will be well placed and have a good argument to say, you didn't know that this wasn't going to happen. Now it's too late to start having this discussion with us. So again, early engagement, early planning will help you in the long run.

Natalie Gjertsen:

And on that point, Kate, I think the other consideration is working with third parties. So there are benefits to running programs in-house and there are benefits to working with third parties to help you with these programs. One of those is sharing the burden. So holding vendors, holding your third parties to account to deliver against KPIs will allow you to be able to help meet those requirements. You can encourage the sharing of risk and reward between the two firms through your contractual arrangements. And I think it's also really important to invest time upfront on that contract with any third party because it provides the ability to put detail into the contract that will help both you and the third party succeed in this programme.

And finally, on working with third parties, encourage collaboration and working together. You know, from my experience in previous big remediations, the us-and-them mentality will kill your programme. The programs that have been successful that are of large scale is when you're collectively working to a single outcome. And that gives you the ability to succeed.

And then finally, just one last point on the operations is to be prepared for the level of exceptions and escalations. We often think about the straight-through flow of cases, but actually it’s those escalations or exceptions to the process that cause a lot of time, backlogs in case movement and need careful planning. So as a rule of thumb, I’d say model your expected level of exceptions so that you get the resourcing needs—and then double it. We always underestimate. So that’s it from me, Samad.

Samad Masood:

Great, let's take some questions. There's some people who have been putting comments on the LinkedIn Live. I'll take this one from Dinesh Shetty first. It's to you, Sha. It's asking, is it worth automating the process given the timeline for remediation? And are there any out-of-the-box remediation platforms that can be bought out by the firms which would be suitable for this? Any thoughts on that?

Sha Ali:

I mean, there are lots of those kinds of platforms that help with remediation, but I haven’t seen or come across one that is specifically for remediation or does a really good job at it. So all the low code, no code platforms like Appian, Pega, et cetera, are really where you need to kind of start with.

But the question around, is it worth it? It definitely is worth it. First of all, the DCS—sorry, the motor-finance scale—is going to be substantial. So the cost of delivery versus the benefit that you'll get—you'll get it. Even if it just breaks even, it’s worth doing it because it's very likely, with the change that I mentioned earlier—the fact that everything's going to change: your process, procedure, policy guidance from the regulator, et cetera—even though everything's going to change, not having technology to help you with that is just going to mushroom the cost very quickly.

And the mistake that people made during PPI is thinking it's just going to be over. Two years later, it's still going. And then three years later, it's still going. And then four years later, still going. I have seen in the media even some cases going through the court recently—and that's, you know, more than a decade after it. Now I’m not saying that’s going to be the case in motor finance, but whatever business case you might have for technology, it’s likely—so long as it can just about wash its face, as in break even—it’s definitely worth doing. Even if it doesn't break even, I would even encourage it because you're going to have all of this change.

So in short, yes, it's definitely worth it. I'm not saying that as a technologist. I'm saying that through kind of empirical data. It's always worth it within remediations. Now the scale is the question, right? Do you have all of the elements I talked about before or just some of them? You must have the data fabric and you must have the workflow. Those are the minimum that you must have. The other things you can start to consider, but once you put those two things in, you're kind of on a good path to then decide whether or not those additional automations are worthwhile. And you can do that based on the scaling that you do from a data analysis perspective.

I hope that will answer the question, Samad.

Samad Masood:

Great, thanks. Thanks, Sha. There's another question from Sharan Bathija as well. What are the potential risks for both firms and consumers if a redress scheme is delayed or the regulatory clarity is further postponed? So, you know, are there risks? What's the challenge if this gets pushed back? Perhaps, Kate, that's something you could start with.

Kate Robinson:

Yeah, I think, you know, if we take this back, this is not an issue that has moved forward at pace. The FCA's original review into the motor finance market and how it operated—including the commission disclosures—goes back to 2017. And then the DCA was banned as a result of that initial work in 2021. So—and now here we are middle of 2025, no real further forward. So in terms of timeline, this is complex. There is a lot at stake in terms of both for consumers and ensuring that trust, but also for the continued growth and effectiveness of the motor market and what ultimately needs to happen in the UK.

I think all that considered, time isn't really the issue at the moment because we've been waiting so long. It would be nice to get some clarity, because with certainty can come better planning, better predictability—we’ll have a better idea of financial resilience both for firms and customers. But my advice to firms and anyone ultimately is: what we need to be really certain of is making the right decision rather than a rushed decision. And I'm sure that the regulator are very conscious of that.

Samad Masood:

Great, thank you. Natalie, any thoughts on that in terms of risks? Kate has painted almost the risk of going too slow in a way or waiting even longer perhaps. Can we quantify that challenge of the uncertainty that we have right now or perhaps even the longer this goes on, the more painful it will be?

Natalie Gjertsen:

I think, not to repeat what Kate said, but I think given the acceleration of events, what we're expecting over the next week or so, the fact that the FCA has been speaking to many vendors already or financial services organizations, I do think that we're going to start to see some direction around what firms will need to do. So I think we're kind of on the movement forward now from this point on.

Samad Masood:

Yeah, also, I guess the fact that everybody's provisioning on their books for the redress, they also want to get it out of the way because that provision is just sitting on their books, right? So there's an imperative for the motor finance companies to close this issue as quickly as possible because otherwise you're just holding on to hoarding cash effectively, which is not good for a business.

And aside from that, you've got all of this anxiety around waiting for the issue to manifest itself and all of the management distraction that's going to occur with people being distracted from their core business to deal with the remediation. So everybody in motor finance, I think—and I don't want to speak for everybody—but would be anxious to resolve this as quickly as possible rather than it be delayed.

So thank you. We're coming to the end of this discussion. You've given some great, great perspective. And I'll just give another minute or two to see if there are any more comments or questions coming in from the audience. In the meantime, I'm going to surprise you with a question. Each of you, from your time in previous redress programs—perhaps PPI—what are the examples you can come up with? Maybe some crazy stories about what can go wrong and what could go wrong this time round. Who’d like to go first?

Sha Ali:

I mean, I’ve got loads of crazy stories, so I can go first, I guess. The data complexity and having to deal with that and then sort of—because you're changing both the—you’re sourcing data from different locations, you're cleansing it, you're processing, et cetera—I mean, I was in a situation where effectively the client, the bank, then asked a bad batch of data and they do a whole bunch of pre-screening and we loaded that data and it effectively messed up every single case in the whole system.

So we had to work 48 hours non-stop through the weekend to kind of unwind all of that because obviously customers are logging into a portal, making updates to cases, etc. So you have to unpick the things that are happening right now live because it's 24 by 7 service and then unwind all of that data, which was a real nightmare. But effectively, the client forgot to—well, not forgot—for whatever reason, which I won't go into, they did not do the data quality check.

So lesson learned there is: at every stage of the process, having systematic data quality is incredibly important. Otherwise, you could end up having to redo cases, which is just soul-destroying. So I would highly recommend data quality checks at every stage you can possibly imagine, and then rechecking whenever you can.

Samad Masood:

Well, what doesn't kill you makes you stronger, I guess, Sha.

Sha Ali:

Yeah, I guess.

Samad Masood:

Kate, Natalie—anything to add?

Natalie Gjertsen:

I'll go next. So I would say don't underestimate the complexity of the programs. In a simpler sense, there's a bit of data, a bit of tech, and some case flow. But we all know how important the program governance, the oversight management of all of those component parts is—individually how difficult they can be, operations needing QC, QA, quality checking, risk and compliance, escalations management. It is going to be a big program. So it's invest now in the planning, even if your planning adjusts as more guidance comes out from the regulator. And also make sure that if you're using or working with any third parties, that you make sure it's clear what everyone is accountable for and that everyone's able to deliver on their side of what they said they would do.

Kate Robinson:

Yeah, I think I just slightly echo what Natalie said. You know, everyone has businesses still to run and running a remediation program alongside your BAU activity is hard work and that needs to be thought through. I think secondly, my overall advice to anyone out there is: whatever decision is made during the course of any kind of remediation program—if that decision is not written down, it did not happen in the eyes of the regulator. So always write down your logic, your methodology, your audit trail will ultimately be your go-to for all work moving forward.

Samad Masood:

Great, thank you. Some great, great final thoughts there. Another question has just come in from Abdullah Khan, asking, are there any examples of organizations that did well during PPI? It appeared everyone was struggling, so it would be good to understand who did well and how they were successful. Now, I won't press you to name names—I know you're all very discreet professionals—unless you want to and can.

Sha Ali:

Yeah, I think I did three or four PPI remediations back in the day. There were some… my primary client, which was a UK domestic bank, did a really great job. And the reason they did a great job—aside from the technologies I delivered—was a point that actually Natalie made. They really worked with us in a fully collaborative way. We had workshops with them, they were making decisions with us, they understood that sometimes we were making decisions with incomplete information, and, you know, if those decisions turned out to be wrong because the information at hand wasn’t right, nobody was looking to go on a witch hunt or anything—we just sort of learnt our lessons and moved on. So I think the ones that did well collaborated very well.

And of course, they really embraced technology and used that technology to kind of get as much automation as possible. The client that I was working with, they gave us a tranche of cases, something like 300,000. And they had more than a million to do in total. And because the calculator that we’d written was so well, we actually did a point integration to do all of their calculations as well. So we were also helping them with their own internal kind of technology, as well as building the technology to deal with the tranche of work that we had got. So yes, there were some that did it.

I would say that collaboration point will probably be the most important, followed by really embracing technology. The embracing technology, I didn’t put first because it is such a kind of table stakes thing now. If you don’t, you’re going to be dead. So you must do that, of course.

Samad Masood:

Great. I don’t know if you have any other answers from the panel. There is another question that I've been told has been asked about what advice do you have for motor finance companies to deal with all the change of address details… issues. I assume that would be one for you again, Sha.

Sha Ali

Yeah, I mean, look, so as I said in PPI, the in-flight cases—of which there were tens of thousands per year, probably a hundred thousand per year that I dealt with—had something like 20% of those customers changing address. We even had to deal with quite a significant number of people who were deceased—their estate—or deceased during the process. So understanding those little nuances in dealing with that is really important.

But on the address thing, if the data within motor finance is up to 18 years old—let’s say the average is five to nine years old—that’s going to mean a lot of people have moved address at that time. So you’re going to have to effectively do a sort of a banking KYC type thing to be able to identify that the person is the person and that the documents that identify those people—their name, their address, etc.—are correct.

And then the other problem you’re going to have is: how does a person who had a motor finance issue several years ago prove that they lived at that address several years ago? So that’s going to require third party data, I think, as well as, of course, reviewing potentially old documents that that customer may have. And that’s going to open you up to quite a lot of fraud. We saw quite a lot of attempted fraud—and potentially some successful fraud—in PPI where people were spoofing identities. So really focusing on digital identity.

Samad Masood:

Thank you very much, Sha. This is the point at which we cut you off because you're giving away too much proprietary knowledge, and people, if they want to know more, should get in touch with you directly—and we'll share your email address to all the attendees.

Sha Ali:

For sure, thank you.

Samad Masood:

Thank you very much. There’s a lot that's going to happen over the coming months and we'll continue to host more conversations like this. So please do connect with us through LinkedIn and to connect with the panel, any of the panel or with the group as a whole. And as things develop, we'll keep you informed. Before we end, I do just want to give the panelists one last chance to have a final few words on this topic. Still much to be decided, but Kate, if I could start with you—what would you say to the audience about the motor finance redress?

Kate Robinson:

I would say the most important thing is to engage with the regulator. Don't be fearful—be honest, be open, say where your issues are, let them know exactly operationally and financially where the key concerns are, and let them make an informed decision based on what the industry is telling them.

Samad Masood:

Great. Natalie?

Natalie Gjertsen:

For me, I would say stay connected. There's information dropping so frequently now, and lots coming through on the mainstream media but also through LinkedIn. So stay connected and prepare. It's going to be big. There's a lot of work that would be beneficial up front now that will help you to be able to be successful when you start delivering against the redress programs in 2026.

Samad Masood:

Great. And Sha, I assume yours is something to do with don’t send bad data?

Sha Ali:

No, I would say—I mean, that's sort of table stakes—I would say that the biggest technical issue from a process perspective is going to be the identity and all the document management that needs to be done, because there’s going to be such old documents and then obviously all the new documents. So really think about how we’re going to deal with that from a technical perspective.

Samad Masood:

Thank you again to our audience. We'll be back. And to our panel, thank you so much for your great insights. And yeah—see you next time. Take care.