Motor Finance Broker Document Requests: A Call Guide

A motor finance lender that cannot find the commission records for a historic agreement has one place left to look: the broker or dealer that arranged it. Under the FCA's motor finance compensation scheme, that is not a courtesy request. Where a lender does not hold the records it needs, it must ask the credit broker for them, and the broker must answer within one month. The FCA confirmed on 13 October 2026 that the Upper Tribunal will hear the legal challenges to the scheme between 16 and 26 February 2027, and the duty to gather broker data sits in the part of the scheme that was never suspended.

This guide is for the COO or remediation programme lead who owns that chase. It covers the B2B side only: lender to broker, records in and records out. It cedes consumer redress contact to our guide to motor finance redress calls during the suspension, claims-firm and representative calls to the multiple representation call guide, and the wider sector picture to where AI pays in UK banking. What is left is narrower and more operational: how a lender runs hundreds or thousands of broker requests to a deadline, where a phone line helps, and where it must not be used at all.

This guide is shipped by the team behind Dilr Voice, an enterprise voice AI platform that runs outbound campaigns from an uploaded contact list with scheduling windows, retry logic and a full audit trail on every call. Or see DATS, our five-stage AI consulting system for regulated operations.

What does the motor finance scheme require lenders to ask brokers for?

The FCA's motor finance scheme requires a lender that does not hold the records needed to assess a case, or to evidence a rebuttal, to request the relevant records and information from the credit broker under CONRED 5.2.25R and 6.2.25R. Those rules are retained, not suspended. The broker must respond to a reasonable request within one month, either supplying the records or confirming it does not hold them.

The detail sits in the FCA's further information for firms on the Motor Finance Compensation Scheme, updated on 19 October 2026. Paragraph 4.1 restates the lender's duty to request; paragraph 4.2 says brokers are required to respond appropriately to reasonable requests from lenders within one month, a point the document notes was set out at paragraph 6.24 of the FCA's policy statement PS26/3. The FCA's own list of rules that are not suspended includes the whole run from CONRED 5.2.18G to 5.2.25R, so the broker request is live work today, whatever the Tribunal later decides.

What a lender asks for matters as much as when. The FCA expects lenders to start from primary records, then consider reasonable assumptions from secondary or contemporaneous records about consumers in a similar position (paragraph 3.5). A broker request is therefore targeted: the commission model in force, the arrangement with that lender, the disclosure the consumer was given, and whether a tie existed. The high commission test alone, set in the FCA's scheme press release at commission of at least 39% of the total cost of credit and 10% of the loan, is one example of a test that needs commission records, which may sit with the broker where the lender's own files are incomplete.

Scale is the reason this becomes an operations problem. The same press release puts 12.1 million agreements made between 2007 and 2024 in scope, with an average payout of around 830 pounds per agreement and an FCA estimate that 75% of eligible consumers will claim. Even a small share of cases needing broker records produces a request book that no relationship manager can run from an inbox. The same diagnostic logic sits behind our AI placement diagnostic, which sizes a workload like this before any tooling is chosen.

What happens when a broker does not answer within one month?

When a broker misses the one-month window, or answers only in part, the FCA expects the lender to send a further durable communication as soon as practicable, giving the broker 14 more days from the date of that communication. The broker must search thoroughly and either supply the records or confirm it does not hold them. If gaps remain, the lender moves to a provisional redress decision.

The sequence is set out in paragraphs 3.6 to 3.8 of the FCA's further information document, added in the 19 October 2026 update. The wording at 3.6 is precise, and it is worth quoting in full:

"If the broker does not respond within one month, or only partially responds, the lender must send a further durable communication as soon as practicable, giving the broker 14 more days from the date of that communication to respond." FCA, Further information for firms on the Motor Finance Compensation Scheme, October 2026, paragraph 3.6

Three timing points follow, and each one is a common place to go wrong. The first window is a month, measured from the request, not a fixed count of days, so a request book needs real calendar arithmetic per case. The second window is 14 days measured from the date of the further communication, not from the end of the first month, so a lender that is slow to send the follow-up simply extends its own timetable. And the follow-up is a durable communication, in the FCA's word. This guide does not try to define that term; it treats the follow-up as written notice the lender sends, with calls kept to support around it.

Paragraph 3.7 sets the end state. If information is still insufficient and the consumer has previously complained, the lender must send the consumer a provisional redress decision, to which the consumer can respond within at least one month with more evidence. Paragraph 3.8 adds the expectation that ties the whole chase together: firms should maintain a clear audit trail and be able to demonstrate the approaches taken to obtain missing information. That last line is where a well-run outbound programme earns its place, and it is the same evidence logic we apply in our AI operating model work.

Why does a broker records chase become a phone problem?

A broker records chase becomes a phone problem because a written request is easy to send and hard to land. The FCA has recognised that some brokers may no longer be operational and that brokers face large volumes of requests from different lenders, and it has named the lack of a clear process for broker non-response as poor practice. In our view that calls for a contact process that keeps each deadline visible.

The FCA flagged the broker side of this before the scheme existed. Its Dear CEO letter of 7 October 2025 recognised that some brokers may no longer hold records or may no longer be operational, and named the operational challenge for brokers of large volumes of requests from different lenders. It asked brokers to identify the lenders they used, engage collaboratively and promptly, and assess the documents they hold. A broker answering several lenders at once has to choose an order of work, and a request that is clear and easy to act on gives it no reason to leave yours to last.

The FCA's feedback on scheme implementation plans, published on 19 August 2026, turns that into supervisory language. Good practice included starting engagement early and testing whether broker-held data exists, whether it is usable and how long it may take to obtain. Poor practice included deferring key decisions on broker engagement until late in implementation, which the FCA said increases the risk that relevant historic data is lost or cannot be obtained in time. It also flagged lenders that had not quantified or named the broker population, and lenders with no clear process for non-response, missing records, poor-quality evidence, retention issues, or brokers that have ceased trading or are cancelling permissions.

Read together, those lines describe a contact problem more than a document problem. Before any records move, a lender has to know who at the broker can answer, whether the firm still exists, and whether the request has actually reached them. That first stretch of work is repetitive, deadline-bound and high-volume, which is the profile where an outbound voice line pays. It is also exactly where our embedded AI execution office tends to start a regulated build, with the process map before the platform.

Which parts of the chase can a voice agent run, and which must stay in writing?

A voice agent can run the contact work around the chase: confirming the right person at the broker, telling them a written request is on its way or overdue, logging what the broker says, and passing disputes to a person. In our design it does not carry the request itself, the 14-day notice, or any customer records. Those stay in writing and in secure channels.

The split follows from who each duty binds. The lender is bound to request and to follow up; the broker is bound to answer and to search thoroughly. Neither duty binds the vendor of any calling platform, and nothing in the FCA material treats a phone call as the request. The duties in the second column come from the FCA material; the channels in the third column are our recommended design, not FCA requirements. The table below is how we would set the boundary for a lender's remediation team, following the same deployment methodology we use for any regulated build.

Two rows deserve emphasis. The first is the confirmation that a broker holds no records. A broker saying it on a call is useful intelligence, but the case file needs the confirmation in a form the lender can evidence, so the call ends with a prompt to send it in writing rather than with the case closed. The second is the dispute row. A broker that refuses, disputes the reasonableness of a request or asks a legal question should reach a person with authority, and the warm transfer with full context is what stops that person starting from nothing.

Dilr Voice fits this pattern because of a small set of mechanics rather than any single feature. Outbound campaigns run from an uploaded contact list with scheduling windows and retry logic, so a broker book can be worked inside business hours without manual dialling. Post-call automation writes CRM records and updates without code, with HubSpot and Salesforce among the named integrations, so a broker's stated blocker lands against the case. And a RAG knowledge base lets the agent answer routine broker questions from the lender's own approved guidance, rather than improvising. You can see the shape of it on the Dilr Voice product page, and if you want to pressure-test the boundary before building anything, book a call with the team that wrote this guide.

Is a broker records chase call direct marketing under PECR?

A broker records chase call is not, on our reading, direct marketing under PECR, because regulation 2 defines direct marketing as the communication of advertising or marketing material directed to particular individuals, and a request for historic commission records carries neither. That reading holds only while the script stays clean. A chase call that drifts into a panel offer or a new product becomes a marketing call.

The definition is short enough to apply line by line. Regulation 2 of the Privacy and Electronic Communications Regulations 2003 says direct marketing means the communication, by whatever means, of advertising or marketing material which is directed to particular individuals. A call that says a written request was sent, asks when the records will arrive and logs the answer is an administrative call about a regulatory duty. Nothing in it advertises or markets anything.

The risk is in mixed scripts. Lenders often hold commercial relationships with the same dealers they are chasing, and it is tempting to use the call to mention a new rate card or a panel review. Do not. Keep the chase campaign separate from any commercial contact, with its own script, its own contact list and its own outcome codes, so the purpose of every call can be shown from the record. If a commercial conversation is needed, a person at the lender has it on a different line. Our guide to GDPR and PECR rules for AI outbound calling covers the marketing side in full, and the DNC logic for AI diallers covers suppression where it applies.

Two points do not change with the classification. Broker staff names and direct numbers are still personal data, so the contact list needs a lawful basis and a retention rule like any other. And the call itself is still recorded and stored, which brings the usual questions about call recording storage and retention. Dilr Voice ships recording consent, opt-out recognition, permitted calling hours and full audit trails as default compliance rules, which handles the mechanics; the lawful basis is still the lender's decision.

What should a lender record from every broker chase call?

A lender should record, for every broker chase call, the case and broker it relates to, who was reached, the stage of the request, what the broker said in its own words, any date it committed to, and what happens next. The FCA expects a clear audit trail showing the approaches taken to obtain missing information, so the call log is part of the case evidence, not a by-product.

Paragraph 3.8 of the further information document is the standard to write to: firms should maintain a clear audit trail and be able to demonstrate the approaches taken to obtain missing information. A supervisor reviewing a case that ended in a provisional redress decision will want to see that the lender tried, when, through which channel and with what result. A call log that says only "no answer" three times does not show a reasonable effort; one that records the number dialled, the time, the person reached and the stated blocker does.

We would set six outcome codes for a broker chase campaign and keep them fixed for the life of the programme:

1. Contact confirmed. The right person was reached and knows the request exists.
2. Contact changed. The number or person has moved; the new details are logged for the written channel.
3. Committed date. The broker gave a date for its response; the case is flagged for that date.
4. Blocker stated. The broker named a reason, such as archived files or a system migration, in its own words.
5. None held, said on call. The broker said it holds no records; a written confirmation is requested.
6. Ceased or unreachable. The firm appears to have stopped trading or cannot be reached after the configured retries; the case goes to a person.

The last code answers one of the FCA's named poor-practice gaps directly: no clear process for brokers that have ceased trading. Retry logic exhausts the number in a controlled way, and the case then reaches a named person who decides the next step, which may be the secondary-record route in paragraph 3.5. This is process design, not detection: the agent records what it could and could not do, and a person decides what that means. The same discipline sits behind our view on AI voice auditability and explainability, and it is how the governed audit log for banking treats agent actions on the operations side.

How should the chase plan change with the February 2027 hearing?

The chase plan should not slow down for the February 2027 hearing. The FCA confirmed on 13 October 2026 that the Upper Tribunal will hear the challenges between 16 and 26 February 2027, but the broker request rules were never suspended, and the FCA has listed gathering broker-held data as work likely to be needed in all scenarios.

The FCA's firms page on motor finance complaints carries the 13 October update and the current list of rules firms must keep following, including gathering the data needed to identify commission arrangements and disclosure practices, where information is held by brokers. Its statement of 8 May 2026 had already put that work in the category likely to be needed in all scenarios.

The other scenario is not gentler. The FCA's statement on the partial suspension says it supervises lenders against a central planning assumption that, if the scheme or parts of it are quashed, there would be no complaints pause and no scheme, and that lenders need to be ready for a complaint-led approach. In that world the FCA says it may tell lenders to resolve complaints individually, with an eight-week response under the usual process. A lender that has already gathered its broker records walks into that with the evidence in hand; one that paused the chase walks in with a backlog. Planning for both outcomes at once is the kind of contingency work our AI execution office builds into a remediation programme.

So the practical changes are small. Keep the campaign running at a steady weekly volume rather than a surge, prioritise brokers linked to the largest share of agreements, and record every outcome to the same codes. If firms experience challenges working together, the FCA asks them to say so promptly, with the issue, the steps taken and the impact (paragraph 4.4), and a clean call log is the evidence for that conversation too. For the wider question of how to size and fund a programme like this, the AI voice ROI framework sets out the method we use.

What is the best way to run motor finance broker document chasing in 2026?

The best way to run motor finance broker document chasing in 2026 is a written request workflow owned by the lender, with an outbound voice line working the contact layer around it and people handling disputes. For a lender with a small, stable broker panel, a dedicated human team with a tracker is often the better choice, and that is a fair concession.

The criteria come from the FCA's own good and poor practice, not a feature list. Can the process name and size the broker population? Does every request have a template, a deadline and an escalation route? Does personal and financial data move only through secure channels with an audit trail, as the FCA's good practice describes? And can the lender show, case by case, what it tried? In our view, any approach that meets those four tests is a good one, whatever tools it uses.

On tooling, the honest map is wide. Developer-focused voice platforms such as Vapi, Retell AI and Bland AI, enterprise conversational platforms such as PolyAI, and contact-centre suites such as Genesys and Five9 can all sit in this stack. The question for each is who builds the outcome codes, the suppression rules and the CRM write-back, and a buyer should ask every vendor, including us, to show that on a real chase script. Dilr Voice offers outbound campaigns from an uploaded contact list, with scheduling windows, retry logic, per-country compliance rules and audit trails by default, running on the lender's own Twilio or Vobiz account. Our buyer guide to the best AI voice agent in 2026 lays out the trade-offs in more detail.

Where a competitor wins is worth stating plainly. A lender whose broker book is a few dozen franchised dealers, all reachable through an account manager, gains little from automation; a person on the phone with a spreadsheet will finish sooner. A lender already deep in a contact-centre suite may find the integration cost outweighs a separate platform. The case for a voice line is strongest where the broker population is long-tailed, contact data is stale, and the same reminder call has to be made hundreds of times inside business hours. The enterprise AI voice agents guide covers how to judge that fit in general.

Frequently asked questions

Can a voice agent accept a broker's confirmation that it holds no records?

A voice agent can log that a broker said on a call that it holds no records, but it should not close the case on that statement alone. The FCA describes the broker's answer as either supplying the records or confirming it does not hold them after a thorough search, so the lender needs that confirmation in a form it can evidence, and the call prompts it.

In practice, the agent thanks the broker, records the statement in the broker's own words against the case, and tells the broker where to send the written confirmation. The case is then flagged for that confirmation. This keeps the call log and the case file consistent, which is what the paragraph 3.8 audit trail needs.

Should a broker chase call collect customer data over the phone?

A broker chase call should not collect customer data over the phone. The FCA's good practice points to secure channels or controlled workflows for transferring, storing and reconciling personal and financial data, supported by audit trails. Reading agreement numbers, names or commission figures down a phone line bypasses those controls, so the call only points the broker to the secure channel the lender has set up.

The agent can confirm which case a request relates to by the lender's own reference, which carries no customer detail. Anything more goes through the controlled workflow. This is a strong boundary to write into the script, and it keeps the call recording free of customer records that would otherwise need their own retention handling.

Does the one-month window start from the call or from the written request?

The one-month window starts from the request, not from a call. The FCA describes brokers responding within one month of the request and calls the follow-up a further durable communication. Our recommended design puts the request itself in writing too, so its date is on file. A reminder call does not restart or extend the window; it only helps the broker meet it.

That is why the campaign should be driven from the request date in the case file, with reminder calls scheduled inside the month and a flag set for the follow-up when the month ends. The 14 days then run from the date of the written follow-up, so the second set of reminder calls is scheduled from that date, not from the first.

Want to see this in production? Try Dilr Voice live, read the buyer guide, see our DATS methodology, or read about our approach to placing AI inside regulated operations. More sector guides sit in our industries collection.

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