FCA Motor Finance Multiple Representation: Call Guide

A motor finance complaint should have one person speaking for the customer. In some cases, the FCA says, it has more than one. A claims management company signs the customer up from an advert, a law firm signs them up from another, and the customer forgets one of them or never understood the first. The lender then receives competing letters of authority for the same agreement, and the phone starts ringing from every direction: the customer asking who is handling their claim, a claims firm asking for an update, and a second claims firm asking the same question about the same file.

The FCA has made this a supervisory issue. Its Dear CEO letter on multiple representation, sent to motor finance lenders on 4 February 2026, sets out the steps it suggests lenders take, and warns that unclear representation delays complaints and can expose customers to unnecessary termination fees. With 12.1 million agreements eligible under the FCA's motor finance compensation scheme, the volume of representation calls is a contact-centre design problem, not an edge case.

This guide is written for the Head of Customer Operations at a motor finance lender. Its scope is narrow on purpose: what a voice agent may record, say and route when representation is unclear, and what it must never decide. It cedes the scheme suspension, outbound redress updates and surge staffing to our motor finance redress call playbook, caller identity checks to the voice AI identity verification guide, and the complaint clock to the DISP complaints handling guide.

This guide is shipped by the team behind Dilr Voice, a multi-agent voice AI platform that runs inbound front desks and outbound campaigns with full audit trails on every call. Or see DATS, the senior-led consulting system that places AI inside regulated operations.

What is multiple representation in motor finance complaints?

Multiple representation in motor finance complaints is the situation where more than one professional representative, usually a claims management company or a law firm, claims to act for the same customer on the same complaint. The lender cannot progress the complaint cleanly until it knows who the sole representative is, so every call about that case needs careful handling of who is speaking and what they may hear.

The FCA's letter calls these firms professional representatives, or PRs, and that is the term this guide uses. The regulator's own diagnosis of the cause is blunt. In the joint warning issued with the Solicitors Regulation Authority on the same day as the letter, the FCA and the SRA say that poor onboarding and due diligence practices, a lack of information to consumers and misleading advertising have contributed to multiple representation. In plain terms, customers were signed up more than once because nobody checked whether they already had a representative.

The commercial incentive explains the volume. The FCA's March 2026 announcement warns that a customer who uses a claims firm could lose over 30% of any money they get, and that there is no need to use one at all. A complaint with a fee attached is worth chasing, and a customer who answered two adverts can end up with two firms each believing it holds the claim.

For a lender, the result is a book of complaints that cannot move. The letter says some lenders have not told representatives or customers promptly when they found duplicates, and that this has produced "a significant volume of complaints where it is unclear who is acting for the complainant". Each of those complaints generates calls, and every call is a chance to disclose too much to the wrong party. That disclosure risk is the reason this is a front-line design question and not only a back-office one. Our wider UK banking AI map sets out where Dilr Voice fits against the redress and complaints surge as a whole.

What did the FCA Dear CEO letter ask motor finance lenders to do?

The FCA Dear CEO letter of 4 February 2026 asks motor finance lenders to identify complaints with more than one representative, then suggests five steps: contact every representative with the customer copied, share enough information for a clear view, explain the implications including any potential termination fees, close duplicates once the sole representative is confirmed, and ask the customer if it stays unclear. The steps are suggestions, not new rules.

The letter, signed by Sheree Howard, the FCA's Executive Director of Authorisations, reinforces a position the regulator set out to lenders on 7 October 2025, and the FCA sent the same message to claims management companies in a parallel letter. Its central expectation is a single sentence:

"Lenders should identify where there is more than one representative for the same complaint and it is not clear who is acting for the customer."

The steps that follow are framed as suggestions, to be applied after a lender has considered its own circumstances and, where appropriate, taken legal advice. Counted from the letter itself, there are five of them, and the diagram below lays them out in the order the letter gives.

One line in the letter matters more than the rest for anyone designing a phone channel. It says lenders "must take care to ensure any information shared is limited to what is necessary to resolve professional representation status", observing legal and data protection requirements. That is the design constraint for every call in this guide. The duty binds the lender, and in practice it binds whichever system answers the lender's phone, which is why the rest of this guide reads like a disclosure policy.

The letter also sets the tone for supervision. The FCA says it will monitor how firms deal with the issue and may intervene where it sees poor practice or unnecessary delay. The broader FCA governance expectations for voice AI apply to any agent placed on these calls, so the controls below are worth writing down before the first call goes live.

Why does unclear representation turn into inbound calls?

Unclear representation turns into inbound calls because every party with a stake in the complaint has a reason to phone the lender. The customer wants to know who is handling their claim and whether they owe a fee, each claims firm wants confirmation that it holds the authority, and the customer often calls again after receiving copied correspondence they do not understand. A single duplicated complaint can produce several calls from different callers.

The structure of the FCA's own expectations adds to the load. The letter asks lenders to copy all representation correspondence to the customer, which is the right outcome for transparency. In our reading, it is also likely to prompt calls from customers who receive a letter naming a firm they do not remember. Its third step, explaining the implications of appointing more than one representative, including any potential termination fees, introduces a topic that customers will want to talk through on the phone.

Termination fees are the second driver. The joint FCA and SRA warning says any termination fee should be reasonable, reflect the work done and be itemised, and that a customer who believes they were unfairly charged should complain to the firm first and then to the Claims Management Ombudsman or the Legal Ombudsman. Note who that binds: the fee rules bind the claims firm or law firm, not the lender. A lender's agent can point a customer to the right route, but it cannot rule on whether a fee is fair. The FCA's statement of 2 July 2026 repeats the consumer warning not to sign up to multiple firms, because each may charge a fee.

The third driver is time. Many motor finance complaints have sat paused for a long period, and a representative signed up in 2024 may not be the firm the customer would choose today, or may not be trading at all. The FCA's feedback on implementation plans flags exactly that, as the evidence section below sets out. In our reading, the stale-representative call, where a customer says they never hear from their claims firm and want to deal with the lender directly, is likely to be one of the most frequent and most delicate calls on the line. The vulnerable customer detection guide covers the signals worth listening for on those calls, because confusion about money and authority is a common trigger.

What may a voice agent record when a caller names a representative?

A voice agent may record what the caller says about representation as a statement, not a finding: the caller's own account of which firm they believe acts for them, whether they recall signing with more than one firm, and what outcome they want. The agent captures those facts in the case record, flags a possible duplicate, and passes the case to the team that resolves representation. It establishes nothing on its own.

The distinction between a statement and a finding is the whole design. The FCA's August 2026 feedback lists, as good practice, the early identification of cases involving more than one professional representative. A voice agent is good at early identification because it asks the same question on every call and logs every answer. It is poor at resolving representation, because resolution means reading letters of authority, checking a firm's status and sometimes taking legal advice.

In a Dilr Voice deployment, that split maps onto a chain of specialised agents. A greeter agent opens the call, and identity checks follow the lender's existing verification policy. A qualifier agent establishes whether the call concerns a motor finance complaint and whether the caller is the customer or a firm. A knowledge agent answers general questions from the lender's own approved documents using a retrieval knowledge base, so it cites the lender's words rather than improvising. Each agent passes context to the next, and post-call automation writes the structured record to the lender's CRM, whether that is Salesforce or HubSpot.

The record itself should be boring and complete. The table below sets out what we recommend the agent captures, what it routes and what it never decides.

Two habits keep the record useful. The agent reads back the firm name it heard, because a misheard name creates a false duplicate. And it records the caller's words, not the agent's paraphrase, because the representation team may need to rely on exactly what the customer said and when.

The same diagnostic logic underpins our AI operating model consulting, which decides which steps an agent owns and which stay with a named person.

What must a voice agent never decide about representation?

A voice agent must never decide which professional representative is valid, never confirm or deny that a particular firm holds authority, never comment on whether a termination fee is fair, and never advise a customer to keep or drop a firm. Those are judgements for the lender's representation team, sometimes with legal advice, and the FCA letter expects lenders to share only what is necessary to resolve representation status.

Each of those boundaries has a reason. Validity depends on documents the agent cannot weigh, such as competing letters of authority with different dates. Confirming authority to the wrong caller is a disclosure about the customer's complaint. Fee fairness is a matter between the customer and the firm, governed by the firm's own regulator. And advising a customer to drop a firm risks steering them, which is exactly the kind of interference the lender cannot justify if the customer later disputes it.

Write the boundaries into the agent's instructions as refusals with a route, not as silence. A customer who asks "which firm should I keep?" should hear a short, factual answer in the lender's approved wording: that the choice is theirs, that the lender is writing to every firm involved with a copy to them, and that a person on the representation team can talk them through the letter. Then the agent offers a warm transfer to that person with the full context of the call, so the customer does not repeat themselves. Our warm transfer and context handoff guide covers how to make that handover land.

How should a lender handle a call from the claims firm itself?

When the caller is a claims management company or law firm, the lender's voice agent should treat it as a business caller asking about a customer's complaint, confirm the firm's identity under the lender's third-party policy, and share nothing about the complaint until the firm's authority is on file and representation is not in dispute. If a duplicate is flagged on the case, the agent records the enquiry and routes it to the representation team.

This is the call where the information-limiting line in the FCA letter does most of its work. A firm phoning to chase an update on a case flagged for multiple representation is, by definition, a party whose standing is not yet settled. Telling it the complaint status, the redress estimate or the name of the competing firm would share more than is necessary to resolve representation status. The safer script acknowledges the call, confirms the case reference, states that the lender is resolving representation in writing with every party copied, and logs the call against the case.

The firm's own obligations sit with its own regulator, and the agent should not try to enforce them. The joint warning says CMCs and law firms are expected to have robust checks in place to confirm consumers have not already instructed another representative, that fees charged by FCA-regulated CMCs must provide fair value under the Consumer Duty, and that SRA-regulated law firms can only bill in line with the agreement the client signed before work started. Those duties bind the firms. The lender's job is to run its own process cleanly and keep a record that shows it did.

Outbound calls need the same discipline. A lender may choose to phone customers, alongside the letters, to explain why they have received copied correspondence. Dilr Voice runs outbound campaigns from an uploaded contact list with scheduling windows, retry logic and an automatic pause at the configured daily end time, and its per-country compliance rules check recording consent, opt-outs and permitted calling hours. The content still has to be factual and neutral, and the scam warnings on the FCA's car finance complaints page are a reason to tell customers how to verify that the call is genuine. The redress call playbook linked above covers outbound design in more depth, and the UK and EU voice AI compliance guide covers the calling rules.

What evidence shows the FCA a lender is handling multiple representation well?

The FCA's August 2026 feedback on implementation plans names what good looks like for multiple representation: early identification of cases, clear processes for checking representative authority and permissions, clear and factual communications where representation is unclear, and legal advice where legal risks arise. Its poor-practice list adds managing duplicate payments, checking that representatives are still trading, and separating complaints from other contact such as data subject access requests.

The FCA's feedback on redress scheme implementation plans, published on 19 August 2026, has a section on multiple representatives. It found that stronger plans detailed how multiple representative issues would be identified early, with clear processes to address them, while weaker plans failed to show how payments would be made effectively where those issues arise. Its four good-practice examples are early identification of cases with more than one professional representative, clear processes for checking representative authority and permissions where relevant, clear, accessible and factual communications with consumers where representation is unclear, and legal advice sought where firms identify legal risks.

The poor-practice examples are more useful, because several of them are tests a phone channel can pass or fail. The FCA lists five:

• a limited process for identifying duplicate or unclear representation;
• an unclear approach to communicating with consumers or their representatives where authority is uncertain;
• limited explanation of how firms will manage the risk of duplicate payments or competing claims;
• failure to check whether professional representatives remain authorised and operational, in particular where complaints have been paused for a long period and the representative may no longer be trading;
• failure to cleanse and validate records to distinguish complaints from other types of customer contact, such as data subject access requests, before identifying cases involving multiple representation.

Three of those five points touch the phone channel directly. A voice agent that logs every representation statement against the right case supports early identification. A consistent, approved script supports clear communications. Tagging each call as a complaint enquiry, a data request or a general query at the point of capture makes the record cleansing easier, and a request for call recordings is a data subject access request with its own route, covered in our guide to DSARs for call recordings. Where a request touches another party's information, the third-party balancing record already sets out the method, so this guide does not repeat it. Duplicate payments and competing claims are a back-office control, not a phone one.

The authorisation check is the one a voice agent should not run. The FCA publishes a register for checking whether a firm is authorised, and the representation team should check each firm named on a flagged case, recording the date and result. Our view is that this check belongs with a person, because a firm that has stopped trading may still appear in correspondence, and the follow-up depends on judgement.

Dilr Voice keeps a full audit trail on every call, and the lender's own systems hold the case file. Together they let a lender show, for any flagged case, when representation was first raised, what the customer said, who it was routed to and when. That is the evidence an AI execution office would review monthly, alongside the governance set out in our enterprise voice AI agents guide.

What is the best way to run representation calls with voice AI in 2026?

The best way to run representation calls with voice AI in 2026 is a narrow agent that identifies callers, records representation statements verbatim, refuses to decide validity or fees, and hands every disputed case to a named representation team with full context. Dilr Voice chains specialised agents and warm-transfers to a human with full context, which suits this pattern, but a lender with a mature contact-centre routing estate may do better configuring its existing platform first.

We would score any option, ours included, on five criteria drawn from the FCA's expectations:

1. Early identification. Does every call about a motor finance complaint ask the representation question and log the answer against the case?
2. Information limiting. Can the agent's knowledge and disclosures be scoped so that a firm whose standing is disputed hears nothing about the complaint? This depends on how the lender's case data is connected, so test it with recorded calls on any platform, ours included.
3. Clean handover. Does a disputed case reach a person with the full call context, without the customer repeating themselves?
4. Record quality. Is every statement captured in the caller's words, with a time, a case reference and a contact type?
5. Approved wording. Are fee, choice and scam answers drawn only from the lender's own approved documents?

Several kinds of system can meet those criteria. Contact-centre suites such as Genesys and Five9 route calls, voice AI platforms such as PolyAI and Parloa run conversational agents, and developer orchestration tools such as Vapi let an engineering team assemble an agent on Twilio. We would concede that a lender which already runs mature intent routing on Genesys or Five9, with a trained representation team and approved scripts in place, may be able to meet all five criteria by adding a representation question to its existing flow, and gains little from a new platform for this one call type. The case for a dedicated agent is strongest where call volume on flagged cases is high, the existing estate cannot scope disclosures by case status, and records are inconsistent across agents. Our AI voice agent buyer's guide sets out the wider comparison.

Whatever the platform, start small. Put the agent on inbound customer calls about flagged cases first, keep claims firm calls with people until the third-party policy is tested, and review a sample of recordings every week. The DATS methodology we use for regulated deployments stages exactly this kind of rollout, and our approach to placing AI inside operations keeps a named owner on every agent.

Can a voice agent tell a customer which representative to keep?

No. A voice agent on a lender's line should never advise a customer which representative to keep or drop, because that choice belongs to the customer and the lender cannot be seen to steer it. The agent can explain, in the lender's approved wording, that the lender is writing to every firm involved with a copy to the customer, and offer a transfer to a person on the representation team.

The FCA letter's final step supports this. If a lender cannot identify the sole representative after reasonable efforts, the letter says the lender should ask the customer what they wish to do. That is a question, not advice, and the answer should be confirmed under the lender's written process.

Does a stale representative from the complaints pause still count?

A representative appointed before the complaints pause may no longer be trading, and the FCA's August 2026 feedback treats failing to check whether representatives remain authorised and operational as poor practice. A voice agent should record a customer's statement that their firm has gone quiet, but the check on whether that firm still exists, and what follows, belongs with the lender's representation team, recorded with a date.

The FCA's March 2026 announcement also says anyone not contacted by a lender has until 31 August 2027 to make a claim, so some customers will call about firms they signed with long ago. Treat every such call as early identification: log it, flag the case and route it. Browse our other industry voice AI guides for related operating patterns.

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