DISCLAIMER
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Close Brothers - Grand Theft Auto

The FCA’s finalized policy statement validates Viceroy’s analysis. Viceroy’s Blue-Sky scenario still suggests Close Brothers will have to more than double its existing provisions.

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March 31, 2026 - The FCA released the final details and adjustments to its Motor Finance Redress Scheme after-market yesterday, March 30 2026. The FCA’s Policy Statement substantially validates our preliminary analysis with regards to Close Brothers’ redress exposure. We have made updates to our scenario analysis to reflect changes from the Consultation Paper to the Policy Statement (PS26/3).

Close Brothers’ redress obligations under PS26/3 erode CET1 capital, leading to near-certain regulatory intervention by the PRA, and force conversion of AT1 notes.

There is now sufficient clarity in relation to lenders’ obligations under PS26/3 that Close Brothers must materially revise its “probability-weighted” provision upwards. Viceroy’s Blue-Sky scenario still suggests Close Brothers will have to more than double its existing provisions.

Unlike PPI where firms managed the payout timetable over nearly a decade, PS26/3 forces crystallisation within a defined window. CBG cannot kick the can, provision incrementally and wait for earnings to absorb the cost. The liability arrives on an expedited schedule the FCA controls, not management.

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