The motor finance investigation, dubbed by some as the “next PPI”, is intensifying scrutiny not only on historic sales practices but also on how lenders handle the surge in customer complaints — particularly from those in vulnerable financial positions. As regulatory uncertainty continues and pressure mounts, lenders must strike a balance between regulatory compliance and compassionate, technology-enabled support. Venu Dumpala, Head of Solutions at Firstsource, outlines how firms can meet these demands by embedding empathy into digital operations.
The fallout from the motor finance investigation will have far-reaching ramifications, not least shining a spotlight on how lenders treat vulnerable customers who may have been mis-sold car finance agreements.
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The key to navigating the expected turmoil is by blending a human-centric approach with a digital-first mindset.
As borrowers seek clarity and redress, they have often been met with frustration due to the ongoing delays in the Financial Conduct Authority’s (FCA) final decision. This regulatory limbo limits lenders’ ability to provide first-contact resolution, placing them in a difficult position: balancing empathetic customer engagement with an evolving compliance landscape.
The lenders that are able to best manage the situation will be those that are able to implement thoughtfully designed digital solutions that prioritise empathy and transparency.
When it comes to the question of identifying and supporting vulnerable customers, lenders must employ proactive detection strategies that extend beyond traditional complaint channels.
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There are several ways in which technology and process can work together to deliver positive outcomes for vulnerable customers:
1. Review historical vulnerability markers
This includes auditing existing flags or annotations on customer accounts (e,g, disclosures of health, financial stress, or communication needs). Integrating this data into discretionary commission arrangement (DCA) related workflows to ensure these customers are automatically prioritised or routed for enhanced care.
2. Implement keyword detection tools
Use natural language processing (NLP) or rule-based keyword checks to scan: written complaints, web forms, live chat transcripts, flag emotionally charged or sensitive terms (e,g, “anxious”, “can’t afford”, “disabled”, “bereavement”, “mental health”).
3. Leverage AI and analytics-based risk indicators
Deploy machine learning models trained on historical complaints to identify patterns of vulnerability. Include triggers such as: changes in payment behavior, missed communications, sudden account activity drops.
4. Use external registries and shared vulnerability indicators
Integrate with external vulnerability registries where available (e,g, Experian’s support service indicators or credit bureau hardship flags). Encourage customers to disclose additional needs via voluntary vulnerability disclosures, prompted at key journey points.
In the fraught environment surrounding the motor finance investigation, making ‘empathy’ an operational requirement is crucial.
Tools like agentic AI and real-time translation offer powerful, scalable solutions to meet this demand.
Agentic AI is capable of operating with autonomous intent, and it significantly enhances how contact centres manage complaints. Agentic systems can initiate, route, and respond to complaint journeys without waiting for manual input. This shortens resolution times, enabling:
- Faster acknowledgement of complaints — a critical early step that builds customer trust
- Timely status updates, demonstrating responsiveness and reducing anxiety
Smart follow-up mechanisms can detect when customers re-engage or escalate and respond immediately, aligning with the FCA’s principle of treating customers fairly — especially during extended regulatory uncertainty.
Agentic AI also ensures the customer doesn’t have to repeat themselves, enabling continuity and a sense of being heard.
Meanwhile, real-time translation promotes inclusive and emotionally intelligent communication.
In the UK’s diverse and multilingual population, language accessibility is a core aspect of empathetic service.
Real-time translation solutions, embedded into voice calls, chatbots, or web portals, help customers express complaints in their native language, ensuring clarity and comfort. They also enable agents to understand the emotional nuance and urgency behind the message.
With machine translation becoming more context-aware, responses can reflect tone, politeness norms, and phrasing that resonate across cultural lines.
Many impacted customers may face compounded vulnerability due to language barriers. Translation services allow them to fully engage in the process, preserving their dignity and agency.
Together, Agentic AI and real-time translation offer a dual advantage: operational efficiency and human-centric service. For motor finance lenders navigating the DCA crisis, these tools can help shift from reactive complaints handling to proactive, inclusive customer care — restoring trust at a critical time.
As the FCA prepares to publish its findings and next steps, a large-scale redress scheme for affected customers is expected on the horizon.
Now is the time for motor finance lenders to ensure they have the required human-centric and digital-first operation that will stand them in good stead during a period of unprecedented upheaval for the sector.
Venu Dumpala is Head of Solutions at Firstsource, a financial services company based in Mumbai, India
