The FCA has issued a Policy Statement entitled “Improving the Complaints Reporting Process” with changes to the complaints returns submitted by firms. These rules are effective from 1 January 2027, and ITC will be using 2026 to prepare for the changes and testing prototypes of the forms to be issued by the FCA. Hopefully by then motor finance commission complaints will be history!
Complaints received by Appointed Representatives are still reported to the FCA on the principals’ returns and therefore it is important that you continue to forward complaints you receive onto ITC on a timely basis so that we can comply with our reporting requirements to the regulator.
The main changes are twofold.
The first major change is increasing the granularity of the complaints reporting, by product and issue of the complaint.
For general insurance, there are over 40 products listed and of relevance to the network are alloy wheel insurance, GAP insurance, motor warranty insurance, and tyre cover, for example.
The issue of the complaint is mapped to one of the four outcomes of the Consumer Duty, again recognising the continuing importance of the Consumer Duty.
For example:
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A complaint about the disclosure of the product information may fall under the Consumer Understanding outcome.
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A complaint about customer service and policy administration may fall under the Consumer Support outcome.
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A complaint about the product performance or features may fall under the Products and Services outcome.
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A complaint about fees and charges may fall under the Price and Value outcome.
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For consumer credit complaints the increasing granularity is on the lender side recognising their greater responsibility for complaints.
You do not need to worry too much about the classification as ITC will do this, as said earlier the main thing is forwarding the complaints to us on a timely basis.
The second major change is about vulnerable customers, another important continuing area of focus from the FCA.
Complaints need to be broken down where the customer is vulnerable or where the complaint concerns the firm’s failure to take the customers’ vulnerability into account.
This makes the identification of vulnerable customers even more important, and ITC will continue its training of your staff and ongoing development of systems so that you can record this.
Although this is quite a big change, at the end of the day complaints are a good source of Management Information, especially when combined with Root Cause Analysis, to identify where things are going wrong or could be improved to give an even better experience for customers. Given the size of our network ITC can benchmark you against your peers and give you feedback on your complaints and any underlying issues.