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Close Brothers - Commission Impossible

Examination of the FCA’s redress scheme suggests that Close Brothers will have to, at least, double its existing provisions. CET1 regulatory capital limits are already at risk.

PLEASE READ IMPORTANT DISCLAIMER

March 16, 2026 – Viceroy Research is short Close Brothers Group (LSE:CBG). We believe CBG has systematically misrepresented its exposure to the FCA’s forthcoming Motor Finance Consumer Redress Scheme. Our review of the FCA’s consultation paper, court transcripts, and independent claims suggests that CBG will have to double its existing provisions (at least).

Viceroy’s “Blue Sky” outcome indicates that equity-holders will be substantially wiped out in a restructure.

Why haven't Close Brothers fully provisioned for the redress already? Because further provisions will breach CET1 regulatory capital restrictions and can create an equity wipeout event.

  • Analysis of FCA consultation paper CP25/27 and Supreme Court case law indicates that Close Brothers’ redress exposure ranges from £572m to £1.07bn, well above its current £300m provision.

  • Close Brothers has exhausted all available measures to sustain its capital base, including the sale of key subsidiaries, Risk Weighted Asset (RWA) reductions, and dividend cancellations.

At these levels, the group’s CET1 ratio will approach regulatory breach thresholds. Any further provisions risk pushing the firm below its minimum capital requirements, triggering:

  • The suspension of AT1 coupons and possible write-down of the assets

  • Credit rating downgrades to junk

  • Regulatory intervention for restructure

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