Every large-scale redress scheme attracts fraud, and the motor finance programme will be no exception. But in this scheme, the most significant risk may not be fraud at all — it may be fairness.
For the first time, lenders must not only process redress at speed and defend every decision, but also identify, support, and evidence fair outcomes for vulnerable customers, as required under the Financial Conduct Authority’s (FCA) Consumer Duty.
Fraud and vulnerability introduce conflicting demands.
Fraud management relies on speed, automation, and firm controls.
Vulnerability requires patience, accessibility, empathy, and human judgement.
These forces inevitably collide, creating a regulatory tension that could define the success — or failure — of the entire scheme.
Move too fast, and vulnerable customers risk being harmed.
Move too slowly, and fraud overwhelms operations.
Striking the balance is now mission-critical.
The Redress Paradox: Speed Meets Sensitivity
Lenders — especially OEM and captive finance providers — will be expected to:
- Process extremely high volumes at pace
- Detect fraud early
- Deliver fair, consistent outcomes on the first attempt
- Justify every decision with a clear audit trail
Yet many OEM lenders face operational constraints that banks do not:
- Smaller teams and fewer specialised functions
- Less mature fraud controls
- Historical data spread across dealer networks
- Customer journeys that are heavily dealer-led
- Systems not designed for forensic auditability
Under these conditions, misclassification becomes a real threat. Poor data quality increases the risk of:
- False fraud flags
- Incorrectly rejected claims
- Delays for customers who most need support
Each misstep increases complaint volumes, heightens frustration, and compounds reputational exposure. For banks, this is an operational challenge. For OEM lenders, it is a brand challenge.
Why Vulnerability Is Now the Centre of Regulatory Gravity
The FCA has made it clear: vulnerable customers are the benchmark for fairness under Consumer Duty.
It is not enough to show good intentions. Lenders must demonstrate — with evidence — that vulnerable customers:
- Were accurately identified
- Received appropriate support
- Experienced fair and timely outcomes
- Were not disadvantaged by automated controls or high-volume workflows
This applies to every customer, every decision, and every audit trail.
While banks may draw on operational muscle memory from earlier remediation programmes, OEM lenders do not have the same legacy infrastructure. Compounding the issue, customers often do not distinguish between:
- The finance arm
- The dealer
- The manufacturer
This means that any perception of unfairness can quickly escalate into a reputational crisis for the brand.
The Core Operational Tension
Lenders may lack the infrastructure banks take for granted:
- Dedicated fraud operations centres
- Experienced remediation teams
- Scalable triage models
- Mature data governance
- High-volume case-handling capabilities
Fragmented dealer-origin data further complicates accurate decision-making.
At the same time, slowing down the process is not an option. The FCA expects:
- Timely outcomes
- Clear communication
- Evidence-backed decisions
Customers expect fairness, transparency, and empathy — particularly when dealing with a complex financial issue.
The challenge is clear: automate defensible decisions without compromising care.
How NTT DATA Helps Lenders Balance Speed and Fairness
NTT DATA’s operating model is designed specifically for high-stakes remediation, enabling lenders to manage the competing pressures of fraud control, vulnerability management, and operational scale.
Our solution integrates:
- AI-Powered Fraud Analytics
Identifies fraudulent behaviours — including synthetic identities, duplicates, and mass CMC submissions — using models tuned to motor finance patterns. - Verified Identity Checks (via Experian)
Reduces false positives and strengthens assurance without slowing down genuine customers. - Vulnerability-Sensitive Routing
Cases involving vulnerability indicators are automatically directed to specialist teams trained in Consumer Duty and empathetic engagement. - Rules-Based Calculation Engines
Ensures consistent, auditable outcomes aligned with methodology — avoiding human error in high-volume environments. - Digital and Accessible Customer Journeys
Streamlined processes that reduce reliance on Claims Management Companies (CMC) and provide direct pathways for legitimate claimants. - UK-Based Specialist Teams for Complex Cases
Where human judgement is required, our teams handle nuanced cases with care, ensuring fairness is upheld. - Full Evidential Audit Packs
Every decision, data source, control step, and rationale is captured, enabling complete transparency and regulatory defence.
With NTT DATA, lenders can:
- Move fast without compromising fairness
- Scale without losing control
- Reduce fraud without harming vulnerable customers
- Protect both the brand and the customer
Fairness Is Now the Standard That Will Be Remembered
Fraud is inevitable.
Fairness is what will define reputations.
The FCA will judge lenders not just on how much compensation they repay, but on how they treat those least able to navigate the process. The organisations that balance automation with judgement, and pace with compassion, will emerge with stronger compliance, stronger trust, and stronger reputations.
Mismanaging fairness, however, can cause damage that outlasts the scheme itself.
Handled well, redress becomes proof of integrity — and a moment for lenders to demonstrate character, leadership, and genuine customer care.