FCA Consumer Duty & F&I Sales — What Dealers Need to Know
- staceywaller
- Feb 2
- 3 min read
The FCA’s Consumer Duty represents one of the biggest regulatory shifts for UK motor dealers selling finance and insurance products. It goes far beyond Treating Customers Fairly and fundamentally changes how dealers must design, sell, evidence, and monitor F&I activity.
For sales managers, F&I executives, and compliance teams, understanding what Consumer Duty means in practice is no longer optional — it’s critical to protecting revenue, reputation, and FCA permissions.
This guide explains what FCA Consumer Duty means for F&I sales, how it impacts day-to-day dealership processes, and what dealers must do to remain compliant.
What Is FCA Consumer Duty?
FCA Consumer Duty is a regulatory framework introduced by the Financial Conduct Authority to raise standards across retail financial services.
At its core, Consumer Duty requires firms to:
Act to deliver good outcomes for customers
Put customer interests at the centre of decision-making
Proactively prevent foreseeable harm
Evidence compliance through monitoring and management information
For motor dealers involved in Consumer Credit and General Insurance, this applies directly to F&I sales activity.
Why Consumer Duty Matters for F&I Sales
Finance & Insurance is one of the FCA’s highest-risk areas, particularly in automotive retail. Consumer Duty places a clear obligation on dealers to show that:
Products sold are suitable for the customer
Sales conversations are clear, fair, and not misleading
Customers understand costs, risks, exclusions, and alternatives
Vulnerable customers receive appropriate support
Outcomes are reviewed — not just processes
In short: how you sell matters just as much as what you sell.
FCA Consumer Duty and F&I Sales Processes
1. Product Governance in F&I Sales
Under Consumer Duty, dealers must demonstrate that finance and insurance products are:
Designed for a defined target market
Regularly reviewed for value and suitability
Withdrawn or amended if customer harm is identified
This applies to GAP insurance, extended warranties, service plans, and finance agreements alike.
2. Fair Value in Finance & Insurance
One of the most challenging areas for dealers is the fair value assessment.
You must be able to evidence that:
The total price paid by the customer is reasonable
Commission structures do not drive poor outcomes
Customers are not paying for cover they do not need or cannot use
Simply offering a product is no longer enough — value must be demonstrable.
3. Customer Understanding at Point of Sale
Consumer Duty places strong emphasis on customer understanding during the F&I conversation.
Dealers must ensure that:
Key product features are explained clearly
Exclusions and limitations are highlighted
Finance terms are transparent and jargon-free
Customers are not rushed or pressured
Sales scripts, menus, and disclosures must actively support informed decision-making.
4. Vulnerable Customers in F&I Sales
Identifying and supporting vulnerable customers is a cornerstone of Consumer Duty.
Dealers are expected to:
Recognise vulnerability indicators (financial, health, life events, capability)
Adapt sales approaches accordingly
Record actions taken to support the customer
Review outcomes to ensure vulnerability was appropriately managed
Failure to evidence this is a significant FCA risk area.
5. Monitoring Outcomes — Not Just Compliance
Perhaps the biggest shift is the requirement to monitor outcomes, not just follow processes.
Dealers must review:
Sales conversion patterns
Cancellation and complaint data
Product suitability trends
Customer feedback and outcomes
This management information must be actionable and regularly reviewed at senior management level.
What Consumer Duty Means for F&I Managers and Dealer Principals
For leadership teams, Consumer Duty introduces clear accountability.
Senior managers must be able to demonstrate that they:
Understand how F&I activity delivers good customer outcomes
Have oversight of risks and controls
Act promptly when issues are identified
Embed Consumer Duty into training, systems, and culture
The FCA has been clear: “We expect to see evidence, not intent.”
How ComplianceTrak Supports FCA Consumer Duty in F&I Sales
ComplianceTrak is designed specifically to help motor dealers meet Consumer Duty expectations across F&I sales.
ComplianceTrak enables dealers to:
Evidence compliant F&I sales journeys
Support clear product presentation and disclosures
Monitor outcomes and identify risk trends
Demonstrate fair value and suitability
Integrate vulnerability identification and support
Produce FCA-ready management information
Rather than relying on manual checks and spreadsheets, ComplianceTrak provides real-time visibility and regulatory assurance.
Key Takeaways for Dealers
FCA Consumer Duty fundamentally changes F&I sales expectations
Good outcomes must be designed, delivered, and evidenced
Vulnerable customer support is non-negotiable
Monitoring outcomes is as important as compliant processes
Systems, training, and management oversight must align
Dealers who embrace Consumer Duty properly will not only reduce regulatory risk — they will also improve trust, retention, and long-term profitability.
Want to Strengthen Your Consumer Duty Compliance?
If you want to understand how ComplianceTrak can support your dealership’s F&I sales under Consumer Duty, speak to our team today.
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