RE: What if.20 Aug 2024 16:29
MV.......there is a link at the bottom of this post to the latest Full Year Results 2023 for Black Horse Ltd where you can find information on it's loan income. Page 2 of the report is interesting reading, copied below.
"Motor Commission Review.
The Company recognised a £324,000,000 provision for the potential impact of the FCA review into historical motor finance commission arrangements and sales.
The Company continues to receive a number of court claims and complaints in respect of motor finance commissions and is actively engaging with the FOS in its assessment of these complaints. On 10 January 2024, the FOS issued its Final Decision on a complaint relating to the Company, as well as decisions relating to other industry participants. On 11 January 2024, the FCA announced a section 166 review of historical motor finance commission arrangements and sales and that it planned to communicate a decision on next steps in the third quarter of 2024 on the basis of the evidence collated in the review. The FCA has indicated that such steps could include establishing an industry-wide consumer redress scheme and/or applying to the Financial Markets Test Case Scheme, to help resolve any contested legal issues of general importance.
Following the FCA Motor Market Review in March 2019, the FCA issued a policy statement in July 2020 prohibiting the use of discretionary commission models from 28 January 2021, which the Company adhered to. The Company continues to believe that its historical practices were compliant with the law and regulations in place at that time.
As noted above, in response to both the FOS decisions and the FCA announcement the Company has recognised a provision of £324,000,000. This includes estimates for operational and legal costs, including litigation costs, together with estimates for potential awards, based on various scenarios using a range of assumptions, including for example, commission models, commission rates, applicable time periods (between 2007 and 2021), response rates and uphold rates. Costs and awards could arise in the event that the FCA concludes there has been misconduct and customer loss that requires remediation, or from adverse litigation decisions. However, while the FCA review is progressing there is significant uncertainty as to the extent of misconduct and customer loss, if any, the nature and extent of any remediation action, if required, and its timing. The ultimate financial impact could therefore materially differ from the amount provided, both higher or lower. The Company welcomed the FCA intervention through an independent section 166 review."
https://www.lloydsbankinggroup.com/assets/pdfs/investors/financial-performance/other-subsidiaries/2023/q4/2023-bh-annual-report.pdf