Regulators have moved upstream. The fight is no longer only about who pays redress, it is about how every claim was acquired in the first place. Provenance is now the asset, taint is the discount.
On 29 July 2026 the Information Commissioner's Office executed search warrants at residential and business premises linked to five companies across Bolton, Burnley, Liverpool, London and Swansea, seizing phones, laptops and documents. The companies under investigation are believed responsible for a combined 170 million motor finance claims text messages sent between September 2025 and May 2026. The ICO acts within a joint taskforce with the FCA, SRA and ASA targeting how motor finance claims are marketed by lead generators, claims management companies and law firms.
What changed in the market, from the public record.
The FCA has confirmed enforcement investigations into two named claims management companies, including allegations that consumers were signed up without consent and that signatures were forged, with the full customer journey now the unit of investigation. Twelve firms operate under agreed voluntary requirements on their motor finance claims activities. The SRA holds 94 open investigations across 68 high volume consumer claims firms and has closed 7. The ASA is investigating motor finance claims advertising by law firms, including fee clarity, exaggerated compensation amounts, and free checker tools. More than 28,000 consumers have exited CMC and law firm contracts free of charge.
An unlawful send does not stay with the sender. It moves through the market with the lead, and it survives every sale.
Contamination stops being a book level rumour and becomes a claim level fact, prevented at the door, cured where found, and proven on demand.
A defined book segment traced backwards, every claim, from retainer to first touch: lead source mapping, consent posture testing, duplicate and prior assignment screening, retainer integrity, and send windows cross referenced against the live enforcement period.
Output: a contamination fraction with a number on it, claim level classification of the entire segment, a cure plan for the middle band, and a signed audit report with the evidence pack behind every classification. Fixed fee, fixed days, named deliverable.
Three documents in one: a collateral revaluation, a defence file that exists before any regulator asks, and the business case for the platform that keeps the number at zero.
In a market where warrants are being executed and no unscreened book can prove it is clean, unprovable is the new dirty. The certified book is the only book that trades at full value, funds at full value, and moves with its reputation attached.
| Loan book under investigation | £16m | GRADE B- |
| Nicholson Jones Sutton position | £2.4m | GRADE C |
| McDermott Smith position | ~£900k | GRADE C |
| Competing security / assignment claims | Live | WATCH |
| Unprovisioned receivable | £17m | GRADE D |
| Horizon Legal lending sub-book | Unquantified | GRADE B- |
| Bondholder position (May 2026 default) | Distressed | WATCH |
| Listing | Category | Indicative | Window closes | |
|---|---|---|---|---|
| North West PCP book · 4,200 claims · funder enforced ILLUSTRATIVE | Salvage Desk | £1.9m | 61h 14m | |
| Yorkshire housing disrepair WIP · single funder exit ILLUSTRATIVE | Salvage Desk | £3.4m | 68h 02m | |
| LF Panel new entrant · Midlands mixed book · seeking £2.8m ILLUSTRATIVE | LF Panel | £2.8m | 71h 45m |
| Monitored entity | Relationship | Signal state | Last filing scan |
|---|---|---|---|
| Courmacs Legal Ltd · CH 13185687 | Primary borrower | WATCH · PS26/3 SENSITIVE | Live |
| Eram Capital Holdings Ltd · CH 15798891 | Security holder | NO ACTIVE SIGNAL | Live |
| + 10 further entity slots available on this seat | Signals fire before public filings surface |
FCA final scheme figures, PS26/3, confirmed 30 March 2026, plus derived site level intensity.
Modelled regional distribution of the 12.1 million eligible agreements. Spikes scale with modelled origination intensity. Drag the year slider to replay the PCP surge, toggle annual or cumulative, and tap any spike for the regional book.
OCC ASSESSMENT | modelled from DVLA regional registration mix and FCA PS26/3 totalsRegional books apply the 2024 DVLA registration mix to the FCA total of 12.1m eligible agreements. Historic regional mix assumed stable, a stated model assumption. Every regional score is OCC Assessment, not sourced data.
Modelled eligible agreements by region, full window 2007 to 2024.
PCP displaced HP as the dominant showroom product between 2012 and 2016. Green points are reported market anchors. Intermediate years are model interpolation.
The franchised network roughly halved across the window while point of sale finance penetration of private new car sales nearly doubled. Origination concentrated into fewer, identifiable sites.
Six findings from the twenty year reconstruction, written for solicitor and funder readers.
PCP moved from a minority product to roughly nine in ten financed new cars in a little over a decade. That steep, one directional curve means the year of an agreement is itself a strong PCP signal. A blank product field on a credit file dated 2017 onwards is overwhelmingly likely to be PCP, and the model scores it accordingly.
The fastest PCP growth, 2012 to 2016, falls entirely within the FCA redress window of 2007 to 2024 and straddles the 31 March 2014 break point between the two schemes. The years when dealers pushed PCP hardest are exactly the years the regulator has priced at the greater loss rate. Volume and liability peak together.
The franchised network roughly halved while finance penetration nearly doubled. Origination did not spread, it concentrated. At today's network size the national average exceeds 2,600 eligible agreements per franchised site. Each surviving dealership is a dense, mappable claims cluster rather than a needle in a haystack.
Only 38% of motor finance customers shopped around, against 94% for motor insurance. For most buyers the dealership desk chose the lender, the product and the rate in a single conversation. That point of sale capture is the behavioural mechanism behind the commission findings, and it is why dealership environment reconstruction matters.
Over 80% of current holders on a new vehicle had used motor finance before. Serial PCP renewal every three to four years means a single client frequently carries two, three or four eligible agreements across the window. Real client value routinely runs at a multiple of the £830 per agreement headline.
Registrations concentrate hard: the South East and North West alone account for over a third of the national mix, and modelled regional books range from £2.25bn down to £0.25bn. Origination effort that follows the spikes reaches the largest books first. The cluster spike map turns that skew into a targeting sequence.
Findings 01, 03, 05 and 06 rest partly on OCC Assessment modelling as flagged in the sections above. Findings 02 and 04 rest on Verified FCA sources.
Move the sliders to test how eligible agreements and redress value distribute across the franchised network. All outputs are OCC Assessment.
Model basis: 12.1m eligible agreements, FCA PS26/3. Site counts from trade network data. Origination share is a model input, not a sourced figure.
FCA Financial Lives 2024 and FCA motor finance consumer research.
11% of UK adults held a motor finance product at or within 12 months of the 2024 survey.
VerifiedOnly 38% of motor finance customers shopped around, against 94% for motor insurance and 72% for mortgages.
VerifiedOver 80% of current holders on a new vehicle had used motor finance before. Multiple agreements per claimant.
VerifiedA credit file shows that motor finance existed. It rarely shows the product type, the sale method or the conditions at the point of sale. The cluster model rebuilds what the file leaves out. All six layers below are OCC Assessment, probabilistic and model derived.
Credit files often list motor finance without saying if it was PCP or HP. The model uses location, purchase year, dealership density and historical sales trends to calculate the probability the finance was PCP, turning a blank field into a likelihood score.
The model rebuilds the point of sale: how many local dealers were actively selling finance, which areas were heavy on PCP promotions, and the competitive pressure at the time of purchase. This supports inference on what the client was likely told or not told.
Where the file holds no agreement date, renewal date or settlement behaviour, the twenty year sales reconstruction maps the client's purchase window, the PCP surge pattern for that year, and the product dominant at the time, producing an estimated timeline.
Credit files carry no mis selling risk signal. The model adds area level exposure risk, mis selling pressure zones, PCP saturation in the postcode, and historical lender behaviours in the region, converting a bare credit entry into a contextualised risk profile.
Where a lender name gives no product signal, the model matches the lender's historic PCP usage, regional sales footprint and product mix in the client's purchase year, inferring the missing product type from lender behaviour.
For each client the model generates:
Simple summary: the cluster model turns missing credit file data into actionable intelligence by rebuilding the client's purchase environment, predicting the product type, and exposing regional mis selling patterns.
National context feeding the cluster layers.
Lender landscape: Black Horse, VWFS and Santander Consumer UK lead originations with no single lender above one fifth of the market. Fragmented lender share is why the lender ambiguity layer matters: a lender name alone rarely identifies the product.
DVLA derived regional new car registrations, the weighting spine behind the cluster spike map, with modelled eligible agreements per region across the 2007 to 2024 window.
| Region | 2024 registrations | UK share | Modelled eligible agreements | Modelled redress book |
|---|---|---|---|---|
| South East | 448,800 | 22.4% | 2.71m | £2.25bn |
| North West | 238,500 | 11.9% | 1.44m | £1.20bn |
| South West | 199,700 | 10.0% | 1.21m | £1.00bn |
| East of England | 189,500 | 9.5% | 1.15m | £0.95bn |
| Scotland | 169,300 | 8.5% | 1.03m | £0.85bn |
| Yorkshire and Humber | 160,100 | 8.0% | 0.97m | £0.80bn |
| West Midlands | 143,300 | 7.2% | 0.87m | £0.72bn |
| London | 137,200 | 6.9% | 0.83m | £0.69bn |
| East Midlands | 134,800 | 6.7% | 0.81m | £0.67bn |
| Wales | 68,700 | 3.4% | 0.41m | £0.34bn |
| North East | 60,300 | 3.0% | 0.36m | £0.30bn |
| Northern Ireland | 49,800 | 2.5% | 0.30m | £0.25bn |
Registration figures and shares are Reported, DVLA derived. Modelled agreements and redress books apply the 2024 mix to the FCA total of 12.1m eligible agreements at £830 average and are OCC Assessment. The full interactive version lives in the cluster spike map.
Every statistic on this tab carries one of three flags.
Confirmed against a live primary source: FCA policy statements, FLA releases, Financial Lives Survey.
Published by trade press or secondary sources and not yet confirmed against a primary register.
Model derived. Probabilistic scores and interpolations built by the cluster model, not sourced data. Pre evidence triage tools, not proof.
Regional scores, postcode saturation and dealership influence ratings produced by the cluster model are OCC Assessment by definition and are flagged as such wherever they appear in Wolf Intel.
| # | Firm | Region | Year | Event | Exposure | Severity | Chain | Wolf AI Signal |
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