ITC - News & Insights

HM Treasury releases policy statement on Appointed Representative regime

ITC Compliance — Wed, 10 Sep 2025 10:00:00 GMT

HM Treasury has released a Policy Statement on the Appointed Representatives Regime.

Update on Motor Finance Cases in Hopcraft, Johnson, and Wrench at the Supreme Court

ITC Compliance — Thu, 07 Aug 2025 08:30:00 GMT

On Friday 1st August, after the markets had closed, the Supreme Court announced it had overturned the Court of Appeal decisions in 2 out of the 3 motor finance commission cases in Hopcraft, Johnson, and Wrench.

Improving Oversight of Appointed Representatives

ITC Compliance — Wed, 09 Oct 2024 04:45:00 GMT

One of the commitments under the FCA’s CEO Nikhil Rathi’s 3-year strategy is “Improving oversight of Appointed Representatives”.

This comes under the FCA’s focus on “Reducing and Preventing Serious Harm”.

The FCA recently published the results of a review of 250 principal firms that it conducted earlier in the year, with the headline being “Oversight of ARs improving but more to do”.

The review found some firms took a tick-box approach to compliance, relied on basic information like website checks, or used self-declarations from their ARs to demonstrate effective oversight.

Surprisingly, 1 in 5 principals had not carried out a required self-assessment or annual review of their ARs.
And whilst ITC was not involved in this work, it compares favourably with the findings.

Good practice points
In addition to actioning the more straightforward items, ITC already has embedded within its business the good practice points raised in the review, such as:

• using a range of management information to assess the risk of harm to consumers or markets, such as quality assurance checks on client files, in-person visits to ARs,
• having regard to Consumer Duty obligations when carrying out annual reviews, such as considering fair value assessments and providing training for staff,
• having a strong understanding of ARs’ business models,
• analysing monthly activity comparing the activity report the AR submits with the principal’s own data,
• reviewing new financial promotions before publication to ensure compliance.

Be confident with ITC
Whilst regulation is constantly evolving such as with the Consumer Duty, with ITC you can be confident that you are partnered with a principal firm that takes its and your FCA compliance obligations extremely seriously.

FCA Principles for Business — One Minute Guide

ITC Compliance — Mon, 26 Aug 2024 04:45:00 GMT

Learn how to adhere to the FCA’s Principles for Business and the standards that should be used by an Appointed Representative (AR) Network Member of ITC Compliance.

What is a Network Member's responsibility?
Ensure that your business is conducted within the 11 Principles for Business that the FCA (Financial Conduct Authority) expects.

The Importance of Fit and Proper Checks

ITC Compliance — Mon, 05 Aug 2024 04:30:00 GMT

Operating product sales with honesty and integrity is not only your duty to your customer but a core regulation of the FCA. The FCA mandates that firms prioritise good and fair outcomes for customers and communicate information that is clear and not misleading.

A recent, albeit extreme, example has demonstrated the importance of having fit and proper checks to ensure that people conducting regulated activities are of good repute. The following story also shows that there are consequences for those who act dishonestly.

Mr. Graham Lilley, a sole trader car dealer and authorised person, has been banned by the FCA from carrying out regulated consumer finance or insurance activities after he was convicted for fraud in 2022 and didn’t tell the FCA.

In 2021, Mr. Lilley assured a customer that he would sell their luxury vehicle at a specific price of £60,000. After misleading the customer about the price for which he would sell the car, he sold it for a lower price and took the customer’s money from the sale of their car. The proceeds, £54,000, were used in his business, Global Car Leasing, which was directly authorised for consumer credit.

Mr. Lilley continued to lie that he was still trying to sell the car, eventually providing the customer with a cheque that consequently bounced.

Obvious Breaches
He acted without honesty and integrity, which is an obvious breach of the conduct rules, which state “You must act with integrity.”

By not telling the FCA about the conviction, he / the firm also breached Principle 11, “A firm must deal with its regulators in an open and cooperative way and must disclose to the FCA appropriately anything relating to the firm of which that regulator would reasonably expect notice.” This was compounded as he was also dealing with the FCA on another matter at the time.

He was sentenced to 12 months’ imprisonment, suspended for 18 months, and received an order to undertake 100 hours of unpaid work.

Keeping your People Fit and Proper
Unfortunately, it was probably easier for Mr. Lilley, as a sole trader, to commit this crime rather than at a larger company with proper systems and controls. And whilst the case was not directly about FCA regulated activities, the FCA is still very interested in financial and non-financial misconduct.

How ITC can help
If ITC is your principal firm, we will act as your liaison and conduit with the FCA. We can help with due diligence to ensure that only fit and proper people are conducting regulated activities for customers, and support you should you need to discipline staff for serious financial and non-financial misconduct matters. Contact ITC today to find out more.

Consumer Duty — One Minute Guide

ITC Compliance — Mon, 24 Jun 2024 04:15:00 GMT

This guide examines Consumer Duty and how ITC Appointed Representative (AR) Network Members can continue to provide a level of service that meets their customers’ expectations.

What is Consumer Duty?
In a nutshell, The Duty is made up of an overarching principle and new rules that firms must follow. It means that consumers should receive communications they can understand, products and services that meet their needs and offer fair value, and the customer support they need, when they need it.

Insights into the FCA Business Plan

ITC Compliance — Mon, 03 Jun 2024 04:15:00 GMT

A few months ago, the FCA published its 2024/25 Business Plan.

There were no real surprises in it, which was to be expected as it is the third year of the FCA’s CEO, Nikhil Rahi’s, 3-year strategy.
The FCA says that the planned programme of work builds on recent progress made to become a “more outcomes-based, assertive and data-led regulator”.   

Unsurprisingly, priorities focus on the Consumer Duty, particularly on protecting consumers by testing if firms are meeting the new requirements. Additionally, the FCA aims to contribute to UK competitiveness and growth and build on the significant progress it has already made to become a world-class data-led regulator, by automating more analytics tools to help detect and respond to consumer harms faster and working with firms on the safe deployment of artificial intelligence.

The FCA will have a workforce of more than 5,000 by the end of March 2024 with an indicative annual funding requirement for 2024/25 of £755m, an increase of 10.7%.

It will continue to deliver the 13 commitments in its strategy, which focuses on preventing serious harm, setting higher standards and promoting competition.

Specific commitments it will prioritise include:

Focus on F&I Regulation

ITC Compliance — Mon, 18 Mar 2024 04:30:00 GMT

By Martin Hill, MD, ITC Compliance

To say that that the automotive Finance and Insurance sector is in a state of flux would be an understatement. Recent developments such as:

- the focus on complaints regarding the Consumer Credit Discretionary Commission model as championed by Martin Lewis, and
- the changes to availability and sales of GAP Insurance from many insurers and product providers

3 Ways Consumer Duty Could Improve Sales Outcomes

ITC Compliance — Mon, 04 Mar 2024 05:30:00 GMT

Introduced in July 2023, Consumer Duty represented a significant shift in the FCA's expectations for higher standards of consumer protection. As much cultural as it is practical within a firm's processes, under the rules firms should be open and honest, avoid harm and support their customers in choosing the right products that suit their needs.

The regulator expects firms to have a clear understanding of the new rules, with any gaps or weaknesses identified and remedied. Many lenders have focused on the basics, such as updating compliance manuals with requisite policies and procedures. However, it’s simply not good enough for firms to say that they are adhering to the rules. It’s important that a firm can evidence a proper framework with robust oversight and can demonstrate that consumers have been provided with the correct documentation and suitable products, at a fair value, leading to good consumer outcomes. ITC works hard with its network member firms to achieve exactly this.

1) Ensuring customers are able to make an informed decision

Providing all customers with sufficient information to make an informed decision about the products and services that firms provide will ultimately lead to greater understanding. Coupled with products that provide the right level of benefits, at the right price, and your sales could increase.

2) Using technology to engage customers and improve the sales journey

ITC’s customer facing platforms are improving consumer engagement to ensure customers are provided with the information required to make an informed decision. This helps the dealer to promote sales, whilst addressing potential customer vulnerabilities along the way. ITC’s management information suite and enhanced reporting ensures that outliers can be easily identified against industry standards, whilst supporting our network through ongoing development.

3) Keeping your products and services fit for purpose

A lot has changed in the industry in recent years with technology and increased vehicle prices, meaning products and services may no longer offer the benefit they once did.

With the FCA’s fair value review, including the continued focus on GAP, firms must measure and demonstrate that consumers are sold and receive products and services that have been designed to meet their needs.

ITC encourages all firms to review their current offering to ensure that the products and service levels fit with their customer demographics.

Conducting value measures on all its network providers, ITC reviews products on an annual basis and provides a monthly value statement so that network members can benchmark RRPs across the industry.

While ITC remains agnostic, being part of Fortegra, a multi-national speciality insurer and A- rated carrier, it has experience to know what good looks like and are proactive in product development.

Get a free health check

ITC’s free, no obligation health check will tell you how your firm is fairing against the requirements of consumer duty. Request online today, or simply speak with one of ITC’s compliance experts today.