The COO View: Ian Beardmore on turning regulatory change into working process

PPL’s new Chief Operating Officer explains why ownership, evidence and process matter across retail finance, motor finance and ongoing FCA obligations

The recent July deadline was a useful reminder that regulatory change does not end on the date it goes live.

The questions have shifted from what has changed to who owns the process? What evidence exists? Can a business show how it is managing the change in practice?

Deferred Payment Credit, the credit behind many Buy Now Pay Later journeys, entered FCA regulation on 15 July, where it is in scope. 

The motor finance redress scheme was partly suspended, but even though there is a pause, that doesn’t mean firms can rest on their laurels. In fact, FCA fee invoices are landing, and they’ve also recently published enforcement data showing that firms can still lose authorisation over regulatory administration, including missed returns, unpaid fees and attestations. 

Staying calm after the storm

For Ian Beardmore, Chief Operating Officer at Product Partnerships Ltd, who founded and ran The Compliance Company for more than a decade before joining PPL, the common thread is not only the rule change itself, it’s whether firms can turn regulatory expectations into something that works in the business day-to-day.

Now Ian has had time to get settled into our Leeds office, we sat down with him and asked him what, from his experience, firms should be thinking about right now.

Ian, what did we learn from the recent July deadline?

Well, July was a big date for everyone in our industry, and now the dust has settled, it showed quite clearly that regulatory change often creates two different questions that need answering, 

The first one is legal or technical: what has changed, who is in scope, and what rules apply?

The second is operational: who owns the process, what needs to happen next, and how can the firm evidence it?

And it’s that second question where firms can come under pressure. 

A business may understand the headline change but might still struggle with the practical steps behind it. 

That might be checkout wording, financial promotion sign-off, complaint routing, lender requests, FCA fee payments, RegData returns, Consumer Duty reporting or management information.

From my experience, the firms in the strongest position are usually those that have clear ownership, clear dates and a simple evidence trail.

Why does operational ownership matter?

Because compliance cannot sit in a document that nobody uses.

A policy might say what should happen. A procedure might describe the steps. But someone still has to take ownership of it, then follow it, review it and prove it happened. Otherwise, it’s not really worth the paper it’s printed on. 

That sounds like a lot to juggle, but in reality, a firm doesn’t need an overly complicated system or a large compliance team. 

In many cases, the issue is much simpler than it might first appear; it’s just important businesses know the answer to the following. 

• Who receives the FCA invoice?

• Who checks whether a financial promotion has been approved?

• Who owns the complaints inbox?

• Who responds to a lender request?

• Who reviews whether staff are following the finance process?

• Who picks it up when that person is away?

Those questions sound basic, but they are often where the real risk sits, so the more you know, the less chance of something unexpected further down the line. 

What does that look like in retail finance?

I’d say the biggest issue for retailers is that BNPL regulation has made many firms look again at how finance appears in the customer journey. 

Many merchants may not need new permissions simply because they offer Deferred Payment Credit as a payment method, but it doesn’t mean they can ignore their finance journey.

The customer still sees the retailer's website, checkout, product pages, emails, paid social, in-store signage and customer service routes.

So from an operational perspective, these are the key questions you should be asking:

• Who approved the current finance wording?

• Has the lender or provider signed off the journey after regulation day?

• Are affiliate and paid social assets still using old copy?

• Where does a finance complaint go if the customer contacts the retailer first?

• What happens if credit checks create more friction or if decline rates change?

This is where I feel retail finance becomes more than just a checkout option. It becomes an operating process that needs an owner, so it is important that businesses can identify exactly who that is and they understand their responsibilities.

What does that look like in motor finance?

Motor is facing different challenges, as the headline story has been around redress. But behind the headlines the operational issue is around records, ownership and response readiness.

The partial suspension of parts of the motor finance redress scheme may have paused some activity, but it has not removed the need for firms to prepare, so firms may still need to identify relevant agreements, gather historic finance, commission and disclosure records, manage customer updates, respond to lender requests and understand which complaints sit inside or outside the scheme.

That may seem like a daunting list, but with planning it’s a practical workload.

For dealers, brokers and lenders, the question is not only whether a payment is due. It is whether the business can locate the information it needs, explain the customer journey and respond consistently if pressure increases.

A simple test to see how quickly you can pull information together by picking one complaint or historic finance agreement at random and see how long it takes to produce the agreement, commission position, disclosure evidence and complaint record.

If that takes too long and finding information is challenging the issue is not only regulatory. It is operational.

Where do firms often fall down?

The most common misconception is that firms assume that if a task is known, it is controlled. 

Knowing there is an FCA return due is not the same as having a named owner, a reminder, a cover process and evidence that it was reviewed.

Knowing a lender owns the finance agreement is not the same as knowing what the retailer should say to the customer.

Knowing there is a complaints process is not the same as testing whether the right complaints are identified, routed and recorded.

Knowing there is a Consumer Duty dashboard is not the same as showing what the data said, what the firm did and whether anything improved.

So the issue is often not lack of effort. It is lack of structure.

Why does evidence matter so much?

Evidence matters because it’s something tangible and irrefutable businesses can rely on if they’re ever challenged. 

Whether that’s by a customer, lender, principal, senior manager or regulator, it needs to show what happened.

That evidence does not need to be complicated. It might be an approval record, a dated checklist, an MI pack, a complaint log, a training record, a file note, a board action or a provider review.

The important point is that effective evidence should be viewed as a key part of the process, not something you need to scramble around for months later when someone asks for it. 

What should firms do now?

I’d say the best place to start is with the recurring tasks and live customer journeys.

Make a list of the key obligations, the date they fall due, the person who owns them, the backup owner, and gather all the evidence you can that shows the task was completed.

Once you’re in a good place with that, then move on to looking at the customer journey and what the customer sees at every touchpoint. And don’t just look at it from a business point of view; scrutinise it through the eyes of your customer. Take off any rose-tinted glasses; be brutal, finding and rectifying issues now can save valuable time in the future.

These are the questions you need to ask. Where does finance messaging appear? Who controls the wording? How are financial promotions signed off? How are complaints identified? What information goes to and from the lender? What management information is reviewed? What happens if the journey changes?

Conducting this exercise is really useful right across the board, from retail, motor, healthcare, home improvement and other customer-facing sectors; the clearer the journey, the more it helps firms move from simply awareness to control. 

How can PPL support?

PPL has many years of expertise in supporting firms with the practical side of consumer credit compliance.

That can include customer journey reviews, financial promotions review, complaints management, RegData, Consumer Duty reporting, FCA applications, Appointed Representative and Direct Authorisation routes, training, provider oversight and platform solutions through Artemis.

The objective is not to make compliance more complicated, the goal is to make it easier for firms to understand what needs to happen, who owns it, how it is evidenced and where support is needed.

Regulatory change may create the deadline; operational control is what carries the business beyond it.