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Allen Ford’s Stunning GAP Insurance Admission – Missing Commission Figures, Unanswered Questions and the FCA Copied In
Allen Ford’s response to our report of misconduct was intended to defend its handling of a GAP insurance complaint. In our view, it has instead exposed a serious problem… the dealership says it does not possess the information about remuneration elsewhere in the distribution chain that we have requested.
The full chain commission remains undisclosed, and the explanation offered for that absence raises serious questions which are every bit as important as the missing figures themselves.
The response, sent by solicitors acting for Allen Ford on 11th September 2026, was copied to both the Financial Conduct Authority (FCA) and the Financial Ombudsman Service (FOS).
This is therefore not our interpretation of an informal conversation with a dealership employee. It is a formal written response, issued on Allen Ford’s behalf, with the regulator copied into the correspondence.
How could the dealership be satisfied that the GAP insurance product represented fair value if it did not understand the remuneration being taken throughout the distribution chain?
And now that those figures sit at the very heart of a complaint, why does its response provide no explanation of any attempts to obtain them?
Those are the questions Allen Ford’s defence leaves unanswered.
The admission at the heart of the response
Responding to our request for the commission and remuneration associated with the GAP policy, Allen Ford’s solicitors state:
“To the extent that your requests seek information concerning remuneration payable elsewhere within the distribution chain or to third parties, our client cannot disclose information that it does not possess. The fact that our client does not hold the information you seek cannot properly be characterised as concealment, deliberate or otherwise.”
That is an extraordinary admission.
Allen Ford seeks to reject our allegations of misconduct, obstruction and deliberate concealment. It says it has engaged with the complaint and supplied documents relating to the vehicle purchase, finance agreement, demands and needs assessment, recommendation and GAP policy.
None of those documents answer one central question: How much of the customer’s payment was absorbed by commission, profit margin and other remuneration throughout the entire GAP insurance distribution chain?
The immediate admission concerns the information Allen Ford says it holds now. That admission inevitably creates a much bigger question about what the dealership knew, what it checked and what evidence it relied upon when selling the product.
Saying that the figures are not in its possession does not resolve those questions.
Instead, it makes the need to answer them even more urgent.
How can fair value be defended without understanding where the customer’s money went?
A customer pays the retail price of a GAP product. They do not separately negotiate prices with the dealership, intermediary, administrator, insurer and any other participant sitting within the distribution chain.
The customer sees one price.
Behind that price there can be numerous payments, commissions, margins and other forms of remuneration.
That is precisely why the missing chain commission is not some peripheral accounting detail.
Our report expressly identified the full chain commission and associated remuneration as the salient facts requiring disclosure.
The concern could hardly be clearer. Was the customer sold a product at a price substantially inflated by remuneration extracted throughout the distribution chain?
If Allen Ford did not know the wider remuneration arrangements, how could it be satisfied that the price paid by its customer represented fair value?
If it did understand those arrangements, or relied upon a meaningful assessment carried out by another participant in the chain, then where is that evidence?
The FCA rules recognise why distribution-chain remuneration matters
The importance of remuneration throughout an insurance distribution chain is not some theory invented by professional claims representatives.
The FCA’s current insurance product governance rules expressly recognise the importance of considering remuneration beyond the amount retained by one individual distributor.
Under PROD 4.3.6AR, distribution arrangements must enable a distributor to identify the impact on overall value of remuneration received by itself or another person in its distribution chain.
The relevant FCA Handbook provisions can be viewed here:
Put simply, the remuneration taken elsewhere within an insurance distribution chain is plainly capable of affecting the overall value received by the consumer.
It is therefore not an irrelevant detail which can simply be dismissed because the information happens to sit somewhere else.
Our challenge to Allen Ford is to produce the evidence which explains the economics of this policy and the basis upon which its value is being defended.
The FCA has already exposed the danger
The significance of these figures is hardly a matter of speculation.
When the FCA announced its intervention into the GAP insurance market in February 2024, it reported examples where 70% of insurance premiums were being paid in commission to parties involved in selling GAP policies.
The FCA also reported that only around 6% of the amount customers paid in GAP insurance premiums was being paid out in claims.
Firms accounting for approximately 80% of the GAP insurance market subsequently agreed to pause sales following the regulator’s concerns about whether the products were providing fair value.
The FCA’s announcement can be read here:
FCA – GAP insurers agree to suspend sales following concerns over fair value
Those were market-wide findings, affecting millions of GAP products.
We consider the FCA intervention to have been inadequate as we’ve discovered commission levels that far exceed 70%, serious suitability issues and evidence of discretionary commission arrangements similar to those uncovered in the motor commission scandal. The intervention sought to fix a market moving forward, but failed to focus on the widespread systemic harm that had already been caused.
The figures relating to this particular policy remain undisclosed.
Against a regulatory background in which the FCA itself discovered extraordinary levels of commission within GAP insurance distribution chains, a complaint specifically alleging excessive and undisclosed chain remuneration demands a proper examination of those figures.
A response which effectively says “we do not possess them” is unacceptable.
It raises an enormous question about whether the product’s value was ever properly understood in the first place.
The absence of the figures cannot sensibly be treated as evidence that the figures would reveal nothing wrong.
Not holding the information is not the same as being unable to obtain it
This is perhaps the most remarkable aspect of Allen Ford’s response.
There is an enormous difference between saying:
“We do not currently possess this information.”
and saying:
“We have investigated the distribution chain, requested the information from the relevant parties and exhausted the reasonable routes available to obtain it.”
Allen Ford’s response says the former.
It does not explain the latter.
There is an obvious starting point.
Ask the businesses involved in supplying and distributing the policy.
Request that the relevant supplier, administrator, intermediary and/or insurer identifies the remuneration retained at each stage of the distribution chain and explains how the customer’s payment was allocated.
At the very least, Allen Ford could seek information from the insurance underwriter about the underlying insurance cost.
That would provide a starting point from which the retail price could be reconciled with the underlying cost of insurance, with taxation, administration charges and other legitimate components separately identified.
Allen Ford’s response identifies no request made to the wider distribution chain.
It identifies no refusal by another participant to supply the information.
It identifies no insurer which has declined to provide the relevant figures.
It identifies no administrator which has refused to explain the distribution economics.
And it identifies no specific obstacle which prevents Allen Ford from attempting to obtain the information.
Instead, the answer is that Allen Ford cannot disclose information that it does not possess.
That is not the end of the question. It is the beginning of it.
If Allen Ford does not know, why doesn’t it know and why does it apparently not want to find out?
This is where Allen Ford’s response becomes particularly difficult to comprehend.
We have raised a complaint which directly concerns the amount of undisclosed remuneration contained within a GAP insurance product.
Allen Ford says it does not possess the information.
So why is the obvious next step not to obtain it?
If enquiries have already been made, Allen Ford should explain what was requested, from whom it was requested and what response was received.
If those enquiries have not been made, then the obvious question is why not?
In our view, choosing to defend the absence of the information rather than explaining how that information will be obtained is wholly inadequate.
And the position becomes even harder to justify when the very regulator which intervened in the GAP insurance market because of concerns about commission and fair value has been copied into the correspondence.
Complaint investigation requires more than supplying existing paperwork
The FCA’s complaint-handling rules are particularly relevant.
DISP 1.4.1R requires a respondent to:
“investigate the complaint competently, diligently and impartially, obtaining additional information as necessary”.
The relevant rule can be viewed here:
The final words are important… “obtaining additional information as necessary”.
The obligation is not simply to open the existing customer file, review whatever happens already to be stored within it and stop there.
Allen Ford points to purchase documentation, demands and needs assessments, suitability records, finance documentation and policy registration information which it says has been supplied.
Those documents may be relevant to some aspects of the complaint, but none of them provide the missing distribution-chain remuneration figures.
A document showing that a customer purchased a GAP policy does not establish that its price represented fair value.
A demands and needs assessment does not explain how much of the customer’s payment ultimately reached the insurer.
A recommendation record does not explain how much money was retained elsewhere within the distribution chain.
A policy registration document does not answer an allegation that excessive and undisclosed remuneration materially distorted the value of the product.
The Ombudsman cannot become a substitute for Allen Ford’s own investigation
Allen Ford’s response concludes by maintaining its position, directing the customer towards the Financial Ombudsman Service.
We do not accept that referring a dissatisfied customer to FOS answers the criticism that essential evidence remains missing.
The FCA’s own complaint-handling framework expects firms to properly investigate complaints and obtain additional information where necessary.
Where a complaint specifically challenges undisclosed chain remuneration, the firm must explain what it has done to establish that remuneration before expecting the customer to pursue another stage of the process.
Forcing FOS escalation without providing disclosure effectively makes FOS the only none legal route to force disclosure.
That is not how an effective complaints process is supposed to operate.
And Allen Ford is still reserving its position on limitation
There is another deeply troubling aspect of the response.
Allen Ford’s solicitors state that the dealership continues to reserve its rights concerning limitation and other available defences.
That creates an extraordinary situation.
The consumer complains about remuneration which was not disclosed.
Allen Ford says it does not possess information about remuneration elsewhere within the distribution chain, and hasn’t provided any evidence to show its efforts to establish the facts.
The complete remuneration picture therefore remains unknown to the consumer.
Yet Allen Ford continues to reserve its right to argue that the complaint has been brought too late.
That argument is doomed to fail at the most basic level.
How exactly was the consumer supposed to discover and complain about the full extent of remuneration when the dealership itself now says that it does not possess the information?
That question goes directly to the concerns we have repeatedly raised about ill-informed attempts to use limitation against consumers in cases involving undisclosed commission.
The consumer cannot reasonably be expected to possess knowledge which was never disclosed at the point of sale and which, more than a decade later, the seller itself says it does not possess.
The FCA was copied into this extraordinary admission
Perhaps the most striking feature of all is the audience.
The response was copied directly to the Financial Conduct Authority.
The regulator therefore has in front of it a written admission in which a dealership dealing with a complaint about undisclosed GAP insurance remuneration states that it does not possess information concerning remuneration payable elsewhere within the distribution chain.
That deserves immediate regulatory scrutiny.
The FCA should be asking what evidence supported Allen Ford’s understanding of the value of the product.
What did Allen Ford know about the wider distribution-chain remuneration?
What enquiries have now been made to obtain the missing figures?
If no enquiries have been made, why not?
How can a complaint centred upon undisclosed remuneration be determined without first establishing what that remuneration actually was?
And how can a limitation defence sensibly be contemplated while the salient financial facts remain undisclosed?
This is a huge red flag.
Allen Ford appears to believe that saying it does not possess the complete remuneration information answers our allegation that the figures have not been disclosed.
It does the opposite.
If Allen Ford did not understand the full remuneration structure associated with the GAP insurance product it was selling, serious questions arise about how it could assess the value being delivered to its customers.
If Allen Ford can obtain that information now but has chosen not to do so, serious questions arise about the adequacy of its complaint investigation.
If it has attempted to obtain the information but has been prevented from doing so, then it should identify the party withholding it and explain exactly what happened.
What is not acceptable, in our opinion, is for the salient figures to remain undisclosed while limitation defences remain reserved.
The FCA intervened in the GAP insurance market because of serious concerns about commission and fair value.
We are now presenting individual cases where consumers are asking the most basic question imaginable… where did their money go?
In this case, the dealership’s answer appears to be that it does not know the complete picture.
For a business defending the fairness of the sale, that position is untenable.
It is a stunning admission.
And with the FCA copied directly into the admission, the regulator can hardly say that it has not been put on notice.
