Two redress letters, no reason given
A lender's automation knew which rule put one complaint outside the redress scheme. It printed the outcome and dropped the reason.
Four in the morning, Saturday. My lender tells me one of my complaints falls outside the FCA’s redress scheme. Sunday, same time, a second letter puts the other one inside. Neither says why.
I have no argument with the automation. Twelve million agreements cannot be worked through by hand.
But look at what the automation did. To place one of those agreements outside the scheme, the system had to apply a rule. Zero APR, commission below the threshold, a loan above the 99.5th percentile, an agreement dated after 1 November 2024. Whichever rule fired, the machine knew which one. It printed the outcome and dropped the reason.
The out of scope letter then pointed me at the complaints process I would now have to use instead. Where the link should have been, it printed [URL_Complaints]. The letter that arrived the next day carried the real address.
Here is my problem. This is the same instinct that built the problem. Commission went undisclosed because disclosure was inconvenient. Exclusions go unexplained because explanation is expensive. Nothing about the behaviour has changed. It has just been through compliance.
The FCA has been running a campaign telling people they do not need a claims management company, because its own research found 27 per cent lack the confidence to complain without one. I understand that 27 per cent rather better than I did on Friday. A claims management company would treat me as its customer. This weekend I was a line in a batch file, pointed at an inbox with nobody’s name on it.
So this gets worse rather than better, and not only in motor finance. Premium finance carries the same commission questions, and it sits on around 23 million policies.
A question for complaints and redress directors. What share of your out of scope letters name the exclusion that applied? If nobody in the building holds that number, you are funding the claims management market and calling it efficiency.