Stage 2 · Calculation Engine
PS26/3 Hybrid Remedy — Step-by-Step
FCA-mandated counterfactual methodology · Click any calculation step for worked example and solution notes
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Scheme 1
Pre-2014 Agreements
6 April 2007 – 31 March 2014. APR adjustment 21%. 100% QA review mandatory. Higher quantum. Legal challenge risk on FCA powers pre-2014.
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Scheme 2
Post-2014 Agreements
1 April 2014 – 1 November 2024. APR adjustment 17%. Sampling QA. Launch 30 June 2026. Lower per-case quantum but far higher volume.
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Johnson Cases
Uncapped Commission Repayment
Commission ≥50% TCC + 22.5% of loan. Full commission repaid + interest. Not subject to standard cap. Rare but high-value. Supreme Court 2025 judgment.
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Counterfactual Rate
PMT Formula & Flat Rate Sourcing
Primary: DT08 Broker Rate Card (F017). Fallback: FCA Reference Rate (F018) where DT08 absent. All substitutions require actuarial sign-off.
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Comp. Interest
BoE Base + 1% · Min 3% Floor
Simple interest from agreement start to payment date. Annual average BoE base rate per year. 3% minimum floor. Consumer cannot challenge the rate (PS26/3 final rules).
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QA Gate
Pre-Offer Sign-Off Requirements
Scheme 1: 100% case review. Scheme 2: Sampling. Senior QA officer signs off. Actuary validates rate methodology. Target <2% error rate before batch proceeds.
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De Minimis
Commission Threshold Exclusions
Pre-April 2014: commission ≤£120 excluded. Post-April 2014: commission ≤£150 excluded. Zero APR deals excluded. Must be documented and notified to customer.
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Data Gap Register
G001–G015 Formal Register
Every data gap formally logged with reason code, source attempted, mitigation method and actuary sign-off. FCA will audit. Gaps >5% of population require FCA notification.
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Dispute Loop
DISP 8-Week Resolution Window
Customer or CMC disputes quantum. FI has 8 weeks to review (DISP). If unresolved, FOS referral. FOS adjudication adds 6–18 months. Reserve impact at P90 accordingly.