CCR009 checklist for motor dealers
Check your FCA permissions
Review the permissions held by the firm and confirm the activity shown on the FCA Register.
- What to check
- Compare the firm’s FCA Register entry with the activity actually taking place in the dealership, including finance introductions and any broker relationships.
- Record that may help
- FCA Register extract, permissions summary and current finance process notes.
- Common issue to avoid
- Avoid relying on memory or one person’s inbox. CCR009 reporting becomes harder when finance information is split across systems with no monthly review.
Confirm the reporting period
Make sure the figures being gathered relate to the correct period shown in FCA RegData.
- What to check
- Check the dates shown in FCA RegData before gathering figures, especially if the dealership year end and FCA reporting period do not feel aligned.
- Record that may help
- RegData schedule, internal reporting calendar and monthly MI file.
- Common issue to avoid
- Avoid relying on memory or one person’s inbox. CCR009 reporting becomes harder when finance information is split across systems with no monthly review.
Review finance introductions
Look at the number and type of finance introductions made during the period.
- What to check
- Check how many customers were introduced to lenders, which lender or broker was used, and whether proposals were accepted, declined or not completed.
- Record that may help
- DMS report, lender portal export, finance proposal log or spreadsheet.
- Common issue to avoid
- Avoid relying on memory or one person’s inbox. CCR009 reporting becomes harder when finance information is split across systems with no monthly review.
Organise lender and broker information
Keep a clear list of lenders, brokers and finance partners used by the dealership.
- What to check
- Keep lender names, broker arrangements and introducer relationships in one place, rather than spread across emails and sales staff notes.
- Record that may help
- Current lender panel, broker agreements and commission statements.
- Common issue to avoid
- Avoid relying on memory or one person’s inbox. CCR009 reporting becomes harder when finance information is split across systems with no monthly review.
Check commission records
Gather records of commission or other income linked to finance introductions.
- What to check
- Check lender commission statements, how totals are calculated and where commission disclosure wording is held.
- Record that may help
- Lender commission statements, invoices, accounting records and disclosure wording.
- Common issue to avoid
- Avoid relying on memory or one person’s inbox. CCR009 reporting becomes harder when finance information is split across systems with no monthly review.
Review customer fees
Identify any fees or charges paid by customers in connection with regulated activity.
- What to check
- Identify any finance-related fees or charges and separate them from normal vehicle sale costs where the records allow.
- Record that may help
- Deal files, invoices and sales ledger records.
- Common issue to avoid
- Avoid relying on memory or one person’s inbox. CCR009 reporting becomes harder when finance information is split across systems with no monthly review.
Review complaints records
Check whether complaints include finance-related issues or consumer credit themes.
- What to check
- Look for complaints about finance explanations, affordability discussions, commission disclosure, declined proposals or customer misunderstanding.
- Record that may help
- Complaints log, email records, outcomes and root cause notes.
- Common issue to avoid
- Avoid relying on memory or one person’s inbox. CCR009 reporting becomes harder when finance information is split across systems with no monthly review.
Check part exchange finance settlement records
Review records where existing finance was settled as part of a part exchange transaction.
- What to check
- Review deal files where existing finance was settled, including settlement figures, lender details and customer communications.
- Record that may help
- Settlement letters, lender confirmations and deal jackets.
- Common issue to avoid
- Avoid relying on memory or one person’s inbox. CCR009 reporting becomes harder when finance information is split across systems with no monthly review.
Confirm RegData access
Make sure the right person can access the firm’s FCA RegData account before the deadline.
- What to check
- Make sure the right person can log in, see the return and understand what information is needed before the deadline is close.
- Record that may help
- RegData user list, login check and internal owner for submission preparation.
- Common issue to avoid
- Avoid relying on memory or one person’s inbox. CCR009 reporting becomes harder when finance information is split across systems with no monthly review.
Complete a final sense check before submission
Review figures for obvious gaps, inconsistencies or missing supporting records.
- What to check
- Compare totals against sales records, lender statements and complaint logs so obvious gaps can be queried before submission.
- Record that may help
- A short review note showing what was checked and where figures came from.
- Common issue to avoid
- Avoid relying on memory or one person’s inbox. CCR009 reporting becomes harder when finance information is split across systems with no monthly review.
Motor trade example
A dealer may have finance proposal data in a lender portal, commission totals in a statement, complaints in a shared mailbox and part exchange settlement figures in deal files. The return is easier when those records can be brought together before the deadline.