MEMA Scope · Assessment
Do motor finance brokers need FCA authorisation?
A firm whose main business is arranging vehicle finance for customers across a panel of lenders, earning commission from the lenders or a fee from the customer. Review the initial view below and answer a few questions to refine it.
- Personalised to your business
- FCA rule references
- Follow-up questions available
Potential regulated activity identified
Credit broking may require full FCA permission
Where credit broking is your main business, limited permission is not available and direct authorisation or appointed representative status is likely to be needed.
Route to consider: Direct authorisation (full permission)
Why this was flagged
- 1Introducing customers to lenders, presenting finance options and helping with applications are all credit broking activities.
- 2Because credit broking is your main business, it is not secondary to something else.
Questions still to resolve
Answer to refine the view. The result updates as you go.
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Do you ever lend your own money or retain a customer’s agreement on your own book?
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Do you help customers settle or restructure existing finance, for example when a vehicle is part-exchanged?The FCA identifies this as debt adjusting or counselling in motor dealer guidance.
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Do you also arrange GAP insurance, warranties or other insurance?
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Do you operate under an authorised network or principal that takes regulatory responsibility for you?
Regulatory basis to examine
Your next steps
- 1Apply for credit broking permission, or confirm an appointed representative arrangement
- 2Put CONC 2.5 broker conduct rules and CONC 4 commission disclosure in place
- 3Set up financial promotions approval and Consumer Duty governance
- 4Review complaints handling and the record-keeping you will need for each lender
Where applications for this model most often fall short
- Evidence that you can disclose commission clearly before the customer commits
- A lender panel and onboarding due diligence file
- Named individuals and a credible compliance oversight arrangement
This is an initial indication from published FCA material, not an FCA determination or legal advice.
If authorisation is required, check the firm’s governance, policies, resources and application preparedness.
MEMA Scope gives an initial view from published FCA material. It is not legal advice or an FCA determination. Automatic matching and typed questions use AI only to choose a profile and to answer from vetted guidance; the assessment itself is never written by AI.
About this business model
A firm whose main business is arranging vehicle finance for customers across a panel of lenders, earning commission from the lenders or a fee from the customer.
Where credit broking is your main business, limited permission is not available and direct authorisation or appointed representative status is likely to be needed.
This page gives an initial view from published FCA and legislation sources. It is not an FCA determination or legal advice. Not your business model? Describe your business in MEMA Scope.
Specialist motor finance broker: frequently asked questions
Does a motor finance broker need full permission?
Where credit broking is your main business, it is not secondary to another trade, so limited permission is unlikely to be available. Full permission or appointed representative status is likely to be needed.
Is commission disclosure required for motor finance brokers?
CONC sets out pre-contract disclosure expectations for credit brokers, including how commission is explained to customers. The detail depends on your model.
What could change the answer for motor finance brokers?
Where credit broking is your main business, limited permission is not available and direct authorisation or appointed representative status is likely to be needed. It can change depending on the answers to questions such as: Do you ever lend your own money or retain a customer’s agreement on your own book? Do you help customers settle or restructure existing finance, for example when a vehicle is part-exchanged? Do you also arrange GAP insurance, warranties or other insurance? Do you operate under an authorised network or principal that takes regulatory responsibility for you?
Which FCA rules should motor finance brokers look at first?
Start with: Credit broking: the activity definition; Perimeter guidance on credit broking; Conduct rules for credit brokers; Pre-contract disclosure including commission. This is an initial view from published FCA material, not an FCA determination.
What are the first steps for motor finance brokers?
Apply for credit broking permission, or confirm an appointed representative arrangement. Put CONC 2.5 broker conduct rules and CONC 4 commission disclosure in place. Set up financial promotions approval and Consumer Duty governance. Review complaints handling and the record-keeping you will need for each lender.
Businesses we check
MEMA Scope covers 32 common business models. Each page explains whether that kind of business may need FCA authorisation, the rules to look at and the routes to consider.
Consumer credit
- Do car dealers offering finance need FCA authorisation?
- Do retailers offering buy now pay later need FCA authorisation?
- Do consumer lenders need FCA authorisation?
- Do debt collectors and debt administrators need FCA authorisation?
- Do debt management and debt advice firms need FCA authorisation?
- Do credit lead generators and comparison sites need FCA authorisation?
- Do rent-to-own and vehicle leasing providers need FCA authorisation?
- Do credit brokers introducing customers to lenders need FCA authorisation?
Payments and e-money
- Do payments apps and payment processors need FCA authorisation?
- Do small payment institutions need FCA authorisation?
- Do e-money issuers and digital wallets need FCA authorisation?
- Do agents of payment institutions need FCA authorisation?
- Do open banking providers need FCA authorisation?
- Do money transfer and remittance businesses need FCA authorisation?
- Do marketplaces handling payments need FCA authorisation?
Insurance
Mortgages
Investments and wealth
- Do financial advisers need FCA authorisation?
- Do discretionary investment managers need FCA authorisation?
- Do investment platforms and wealth-tech firms need FCA authorisation?
- Do crowdfunding and peer-to-peer lending platforms need FCA authorisation?
- Do corporate finance boutiques need FCA authorisation?
Other regulated activities
- Do claims management companies need FCA authorisation?
- Do funeral plan providers and sellers need FCA authorisation?
- Do introducers and referral partners need FCA authorisation?
- Do international firms entering the UK need FCA authorisation?
- Do accountants and solicitors giving financial advice need FCA authorisation?
Want a consultant to look at your facts?
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Email: contact@memaconsultants.com