UK competition law for the sector
On 1 June 2023 the Motor Vehicle Block Exemption Order (MVBEO) came into force in the UK (referred to in the article "The Agency Model: Further Update" by Mark Gipson). This "MVBO" (which is mainly aftersales-specific) – together with the existing, more general, Vertical Agreements Block Exemption Order or "VABEO" (which covers sales) – now comprise the UK domestic competition regulation for the sector.
As the sector is accepted to be "in transition" the UK Government has limited application of the MVBEO to six years (expiring 31 May 2029) when it may be replaced by new regulation that properly reflects the market and competition issues then relevant to the sector. Helpfully, the final version of the Competition and Markets Authority (CMA) Guidance on the MVBEO was expanded to assist beyond the (aftersales-focused) MVBEO itself to also consider vehicle sales.
Consumer Duty
31 July 2023 sees the launch of the FCA's new Consumer Duty, with its higher and clearer standards of consumer protection across financial services and requirement to put customer's needs first (replacing its old "treating customers fairly" principle). The changes required in the motor finance model are significant for all financial services firms, which covers motor dealers too. Hopefully dealers will have done what they need to have by the deadline of 31 July – and we will then wait and see what impact the new Consumer Duty has on claims and complaints in the sector, fingers crossed!
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