C
CurvestoneMotor Finance Redress
3 regulatory inputs pending Northridge Capital Finance Ltd Demo
Monitoring

Source Document

Case Intake

Cases are ingested automatically from multiple channels and queued for processing

Intake Channels
🔌
API Integration
Direct feed from lender complaint systems via REST API
📊
Bulk CSV Upload
Batch upload of case files from lender exports or CMC referrals
🌐
Portal Submission
Consumer or CMC direct submissions via web portal
Case Feed — Live Queue
RefConsumerVehicleChannelReceivedStatus
MF-2024-00412Sarah MitchellVW Golf — KF18 YBNDirect complaint14/01/2026Complete
MF-2024-00413James ThorntonFord Focus — BG19 LMRCMC referral14/01/2026Complete
MF-2024-00414Priya SharmaAudi A3 — DN17 XWPAPI feed14/01/2026Processing
MF-2024-00415David WilliamsBMW 3 Series — FL20 KHDFOS referral14/01/2026Awaiting Review
MF-2024-00416Emma RichardsonVauxhall Corsa — HJ18 NPRBulk CSV14/01/2026Queued
MF-2024-00417Mohammed Al-RashidMercedes C-Class — KM19 TBCScheme opt-in15/01/2026Queued
MF-2024-00418Rachel CooperNissan Qashqai — DF20 VWXAPI feed15/01/2026Queued
MF-2024-00419Thomas BurkeKia Sportage — WR18 ABCCMC referral15/01/2026Queued

Analysis

Case detail, document extraction, and AI-powered data analysis

CaseMF-2024-00412
ConsumerSarah Mitchell
VehicleVW Golf — KF18 YBN
Complete
Case Detail
⚡ Case data auto-populated from lender records and complaint submission
Consumer Details
Agreement Details
ℹ FCA Alignment: This intake form mirrors the FCA's recommended complaint template. Fields map directly to the data points required for scheme assessment under CP25/27.
Documents
📁
Drop case documents here or click to browse
Finance agreements, commission schedules, broker arrangements, disclosure documents — PDF, TIFF, DOCX
Uploaded Documents
PDF
HP_Agreement_KF18YBN_2018.pdf
2.4 MB
✓ Extracted
PDF
Commission_Schedule_Sept2018.pdf
340 KB
✓ Extracted
PDF
Dealer_Broker_Agreement_Greenfield.pdf
1.1 MB
✓ Extracted
PDF
Customer_T&Cs_v4.2.pdf
890 KB
✓ Extracted
Extraction Results
PDF
HP_Agreement_KF18YBN_2018.pdf Confidence: 98%
Agreement typeHire Purchase (PCP)
Cash price£14,200.00
Deposit paid£2,000.00
Amount of credit£12,200.00
Total charge for credit£4,880.00
Total amount payable£17,080.00
APR12.9%
Flat rate6.8%
Monthly payment£283.33
Term48 months
Optional final payment£4,200.00
PDF
Commission_Schedule_Sept2018.pdf Confidence: 97%
Commission typeDiscretionary Commission Arrangement (DCA)
Commission paid to broker£2,196.00
Base rate offered to dealer4.9% flat
Rate charged to customer6.8% flat
Broker adjustment+1.9%
Commission as % of cost of credit45.0%
Commission as % of loan amount18.0%
PDF
Dealer_Broker_Agreement_Greenfield.pdf Confidence: 94%
Arrangement typeExclusive panel — single lender tie
Effective datesJanuary 2016 — December 2020
Exclusivity clause"Dealer agrees to offer [Lender] finance as the primary option to all customers"
Volume commitmentMinimum 40 agreements per quarter
PDF
Customer_T&Cs_v4.2.pdf Confidence: 99%
Commission disclosure foundYes — Clause 9.3
Disclosure of amountNo
Extracted text"The dealer may receive a commission or other payment from the lender in connection with this agreement"
Disclosure of mechanism (DCA)No
Disclosure of broker adjustmentNo
Separate disclosure documentNo

Assessment

Sarah Mitchell — MF-2024-00412

Assessed
📋 Regulatory Parameters — FCA Input Requested
The following thresholds are currently set to CP25/27 consultation values. These parameters are configurable and will be updated when final rules are published. We welcome FCA guidance on whether these reflect the intended scheme design.
High commission: % of total cost of credit≥ 35%CP25/27 proposed
High commission: % of loan amount≥ 10%CP25/27 proposed
Disclosure adequacy standardInformed consent (Supreme Court test)Case law
Severe classification triggerAll 3 unfair features + inadequate disclosureCP25/27 proposed
1. Discretionary Commission Arrangement (DCA)Unfair Feature Found
⚠️DCA Present — Broker adjusted flat rate from 4.9% (base) to 6.8% (+1.9%), generating £2,196 commission. Customer was not informed of the DCA mechanism or the broker's ability to adjust the interest rate.
Evidence

Commission schedule confirms DCA in operation. The broker exercised discretion to increase the customer's flat rate by 1.9 percentage points above the base rate, directly increasing the total cost of credit by £2,196. No disclosure of the DCA mechanism was provided.

Source: Commission_Schedule_Sept2018.pdf, lines 4–12

Confidence: 98%
2. High CommissionUnfair Feature Found
⚠️High Commission — Both FCA thresholds exceeded. Classified as high commission under CP25/27.
Threshold Analysis
Commission as % of total cost of credit45.0%EXCEEDS ≥35%
Commission as % of loan amount18.0%EXCEEDS ≥10%

Source: Commission_Schedule_Sept2018.pdf; HP_Agreement_KF18YBN_2018.pdf

Confidence: 99%
3. Contractual TieUnfair Feature Found
⚠️Exclusive Arrangement — Broker agreement confirms exclusive panel arrangement between Greenfield Motors and lender from Jan 2016 to Dec 2020.
Evidence

The dealer-broker agreement establishes an exclusive panel arrangement effective January 2016 to December 2020. The customer's agreement (September 2018) falls within this period. The customer was not informed, limiting access to competitive finance offers.

Source: Dealer_Broker_Agreement_Greenfield.pdf, clause 3.1

Confidence: 94%
Disclosure Assessment
Disclosure Analysis
Overall assessmentInadequate What was disclosedGeneric clause in T&Cs stating commission "may be payable" (clause 9.3) What was NOT disclosedCommission amount (£2,196), commission mechanism (DCA), broker's ability to adjust interest rate, exclusive broker-lender tie Informed consentNo Legal assessmentFails the informed consent test established by the Supreme Court (Johnson v FirstRand, August 2025).
Overall Case Classification
SEVERE
All three unfair features present (DCA + high commission + exclusive tie) with inadequate disclosure
Redress tier: Full commission refund + compensatory interest
Overall confidence: 96%Human review required: No

Redress Calculation

Full commission refund + compensatory interest (severe case)

LineDescriptionAmount
ACommission paid to broker £2,196.00
BLess: fair commission estimate (non-DCA equivalent)£0.00
CNet commission refund (A − B)£2,196.00
DOverpayment periodSept 2018 — Sept 2022 (48 months)
ECompensatory interest (avg base rate + 1% p.a.)£412.80
FLess: income tax on interest (20%)−£82.56
GTotal redress payable£2,526.24
Calculation methodology follows CP25/27 proposed rules. Compensatory interest calculated at the average Bank of England base rate during the overpayment period plus 1%, compounded annually.
📋 Calculation Methodology — FCA Input Requested
Two elements of the redress calculation would benefit from FCA guidance to ensure alignment with the final scheme rules:
Compensatory interest rateAvg base rate + 1% p.a.CP25/27 proposed
Fair commission baseline (Line B)Currently set to £0 for severe DCA casesAwaiting guidance

For standard (non-severe) cases, the methodology for calculating what commission would have been paid absent the DCA is a key open question. Should this be based on the lender's non-DCA rate card, an industry average, or another benchmark?

Scenario Comparison
If classified as Standard (not Severe)
£1,428.60
Partial commission refund (65%) + compensatory interest.
If DCA only (no high commission, no tie)
£879.36
Difference between DCA rate and non-DCA equivalent + compensatory interest.

Consumer Outcome

Generated outcome letter for consumer review and approval

Northridge Capital Finance Ltd
Ref: MF-2024-00412
Scheme ref: FCA-MFS-2024-00412
16 January 2026
Ms Sarah Mitchell
42 Oakwood Drive
Caversham, Reading
RG4 7LP

Your motor finance complaint — our findings

Dear Ms Mitchell,

Thank you for contacting us about your motor finance agreement (reference NRF-HP-2018-041587) for a Volkswagen Golf, registration KF18 YBN, taken out on 22 September 2018 through Greenfield Motors, Reading.

We have assessed your complaint under the FCA's Motor Finance Consumer Redress Scheme. Following a thorough review of your agreement and associated documentation, we have identified the following:

What we found

  • Discretionary Commission Arrangement (DCA): The broker who arranged your finance had the ability to set your interest rate, and chose a higher rate than the base rate offered to them.
  • High commission: The commission paid to the broker represented 45% of the total cost of credit — significantly above the threshold for what the FCA considers fair.
  • Exclusive arrangement: The dealer had an exclusive arrangement with a single lender during the time of your agreement, which limited the finance options available to you.

You were not adequately informed about these arrangements.

Your compensation

Based on our assessment, we are offering you compensation of:

£2,526.24

This is made up of:

  • Commission refund: £2,196.00
  • Compensatory interest: £412.80
  • Less income tax on interest (20%): −£82.56

What happens next

If you accept this offer, please confirm within 28 days and we will arrange payment. If you do not accept, you retain the right to refer your complaint to the Financial Ombudsman Service (FOS).

Yours sincerely,

Motor Finance Redress Team
Northridge Capital Finance Ltd

Consumer Communication Timeline
Complaint received
14 January 2026
Acknowledgement sent
16 January 2026
Assessment completed
16 January 2026 — automated
Outcome letter ready — awaiting approval
16 January 2026
Consumer response window (28 days)
—
Payment processed
—

Audit & Monitoring

Full audit trail and scheme-wide performance monitoring

Case Audit Trail — MF-2024-00412
TimestampActionDetailActor
2026-01-14 09:14:22Case createdComplaint received via direct submissionSystem
2026-01-14 09:14:23Documents ingested4 documents uploaded (total 4.73 MB)System
2026-01-14 09:14:31Extraction completeAll fields extracted, confidence ≥94%AI Engine v2.4
2026-01-14 09:14:38Scope validatedAgreement in scope (Sept 2018, HP, regulated)Rules Engine
2026-01-14 09:14:52DCA assessmentDCA found — broker adjustment +1.9%AI Engine v2.4
2026-01-14 09:15:04Commission assessment45.0% of CoC, 18.0% of loan — HIGHRules Engine
2026-01-14 09:15:21Tie assessmentExclusive arrangement confirmed (2016–2020)AI Engine v2.4
2026-01-14 09:15:34Disclosure assessmentInadequate — generic clause onlyAI Engine v2.4
2026-01-14 09:15:46ClassificationSEVERE — all 3 criteria + inadequate disclosureRules Engine
2026-01-14 09:15:52Redress calculated£2,526.24 (full refund + compensatory interest)Calc Engine
2026-01-14 09:15:57Outcome letter generatedTemplate: SEVERE_OUTCOME_v3System
2026-01-14 09:15:59Processing completeTotal time: 97 secondsSystem
Case fully assessed in97 seconds
Scheme-wide Monitoring Dashboard
Total cases processed
244,891
Cases requiring redress
164,482
67.2% of total
Average processing time
~90s
per case (vs ~45 min manual)
Consistency score
99.7%
same inputs → same outputs
Flagged for human review
22,040
9.0% of total
Total redress liability
£171.4M
Classification Breakdown
28%
39%
9%
14%
10%
Severe (28%) Standard (39%) Manual review (9%) Defensible (14%) Out of scope (10%)
Processing Volume — Cases per Day
Week 1Week 2Week 3Week 4Week 5Week 6Week 7Week 8
Quality Assurance
✓Consistency check: 500 cases re-assessed with randomised ordering — 99.7% identical outcomes
✓Edge case detection: 22,040 cases (9.0%) flagged for human review based on confidence thresholds <85%
✓False positive audit: Sample of 200 'defensible' cases manually verified — 96% agreement with AI classification

Admin — Automation Rules

Configure confidence thresholds, routing rules, and automation boundaries

📋 Automation Governance — FCA Input Requested
The platform allows lenders to configure the level of automation applied to case assessment. We'd welcome the FCA's view on appropriate governance boundaries for AI-assisted redress processing — for example:
  • Should severe cases (highest redress tier) always require human review before an outcome letter is sent?
  • What minimum confidence threshold is appropriate for fully automated processing?
  • Are there case characteristics (e.g. vulnerable customers, high-value agreements) that should always be routed to a human reviewer regardless of confidence?

These settings are fully configurable per-lender. The defaults shown below reflect our recommended starting position.

⚙ Global Confidence Threshold

Cases with an overall confidence score above this threshold will be eligible for fully automated processing. Cases below will be routed for human review.

50% 99% 90%
🔀 Classification Routing Rules
Severe — all 3 unfair features + inadequate disclosure
Standard — 1–2 unfair features
Defensible — no unfair features found
Out of scope — agreement not within scheme parameters
🎯 Per-Criterion Confidence Thresholds
CriterionMin Confidence for AutoBelow Threshold Action
DCA Detection 85%
High Commission 90%
Contractual Tie 80%
🦺 Review Queue Routing
Commission amount exceeds £5,000→ Always human review
Multiple unfair features detected (2+)→ Senior review
Redress amount exceeds £10,000→ Escalate to senior
Document extraction confidence below 80%→ Manual document review
Consumer is a vulnerable customer (flagged)→ Escalate to senior
📊 Current Configuration Summary
Global confidence threshold90%
Estimated auto-processed cases~78% of volume
Estimated routed to reviewer~16% of volume
Estimated escalated to senior~6% of volume
Average throughput at current settings~6,200 cases/day