Finance and insurance is increasingly being defined not just by compliance, but by the quality of the advice process, according to speakers at the 2026 F&I Virtual Summit on Tuesday. Panellists said the best F&I professionals combine product knowledge, good record-keeping, and a customer-first approach to support informed decisions and better outcomes.
The panel consisted of Billy Seyffert, chief operating officer of Moonstone Compliance; Andrea Arenz, senior adjudicator at the Ombud for Financial Services Providers; and Zelna Marx, group F&I manager at CFAO Mobility.
Seyffert distilled the essence of a good Record of Advice (ROA) into a simple operational test: if a third party reads the ROA without having been present at the client meeting, they should be able to understand what was discussed, what needs were identified, what was recommended, what was taken up, and what was offered but not taken.
He said it is often the part of the recommendation that was offered but not taken up that leads to complaints. Customers do not complain when policies perform; complaints arise when they declined certain products, later believed they had those benefits, and there is no recording of what was discussed and decided. He said that if a third party can see from the ROA what was spoken about, offered, and elected, the dealership is in a better position.
Seyffert contrasted this with “do the deal now, do the paperwork later”, where forms are pre-populated and the client is asked to “sign here, sign here, sign here”. He said that is not a proper ROA, because the client may not remember what was discussed. He reminded the audience that the original purpose of the ROA was to allow the client to review the advice outside the pressure of the sale and confirm whether it reflects what they want.
A solution, not just a product
From a dealership perspective, Marx underlined the ROA’s importance as evidence. She said it is the document that will stand in court to show whether proper advice was given and whether the client is in the right or wrong.
Marx said she tells F&I staff to “sell a solution, not a product”, starting with the client’s needs, financial situation, and objectives. When she reviews ROAs, she sometimes finds copy-and-paste records, with the same sentence repeated like a pattern. In her view, that is not advice, but a shortcut aimed at ticking boxes.
Marx linked many complaints to when and how the F&I interaction takes place. She said customer engagement should start at the beginning of the purchase, not when the vehicle is about to be delivered. She recommended that ROAs reflect when interaction with the customer began, which products were identified and discussed, and that the customer had enough time to make an informed decision.
She said F&I managers are sometimes pulled into the transaction only at delivery. When that happens, the customer may not have had sufficient time to decide what they need and do not need. If F&I is treated as a last-minute tick-box exercise, she said, this is where complaints come from, where customers are unhappy, and where the brand and profession are tarnished.
She also advised F&I managers to correct omissions in ROAs as soon as they are noticed. For example, if service intervals were not recorded, she said they should go back, add the information, inform the customer, ensure the client receives updated documentation, and inform the key individual so potential complaints can be addressed proactively.
What the FAIS Ombud looks for in dispute evidence
Asked what evidence is most critical in disputes, Arenz outlined the FAIS Ombud’s approach. She said the office usually requests the ROA, the quotation, telephone recordings, and email correspondence. However, she emphasised that the existence of these documents is not, on its own, decisive. The key questions are whether the records are of sufficient quality and reliability, and whether they allow an assessment of the substance of the interaction.
Arenz said the FAIS Ombud looks for evidence that there was actual engagement with the client. She pointed to section 7 of the FAIS General Code of Conduct, which requires a general explanation and a reasonable explanation of material terms, and to the definition of what counts as material terms. She added that section 9, which requires an ROA, shows that the FAIS framework envisages discussion, explanation, and engagement about the product, rather than merely handing over documents.
Professionalising F&I: advice, agency, and ethics
The panellists shared different perspectives on what it means to professionalise the F&I role.
From the ombud’s perspective, Arenz said the aim is that when customers leave a dealership, they should understand the products they have purchased, the nature of the benefits and limitations, whether the products meet their stated needs, and whether the products perform as they were led to expect.
She said complaints often indicate that although benefits were discussed, limitations were not properly explained, and customers did not experience a sufficient engagement to understand the exact features of the product.
She added that F&I professionals who succeed will likely be those who see compliance as a tool to enhance their value proposition, deepen client understanding and trust, and improve the F&I process.
Seyffert framed professionalisation in terms of the principal-agent relationship. He said the client, as principal, instructs the F&I manager, as agent, to source solutions to their financial needs. To be professional, he said, the F&I manager must be knowledgeable, act in the client’s interests, have a proper discussion, record the minutes of the meeting in the ROA, and provide informed advice.
He said this means knowing the suite of products that can be offered and selecting the one that is best for the client, not merely the simplest or easiest product from a process perspective. F&I managers are working for the customer, not the dealership, and should behave accordingly.
Marx said she believes in driving a culture of ethics and good behaviour across the business, from the dealer principal and sales manager through to salespeople and F&I managers. Everyone, she said, should respect that there are legislative requirements and that the F&I manager’s role is to mitigate risk and ensure FAIS and fit-and-proper requirements are met.
She said strong collaboration and good relationships between F&I and sales teams are associated with high levels of customer satisfaction, because there is mutual respect and a shared aim of looking after the customer.
She also highlighted the importance of product and brand knowledge, knowing the customer and building trust. She said a neat office helps create a professional environment and said visible paperwork should not be left lying around.
Digital channels and the shift towards outcomes-based oversight
Seyffert said digitisation can make compliance easier. He noted that FAIS is in its last iterations and that the Conduct of Financial Institutions Bill will take over, shifting the regime from rules-based to outcomes-based. In that context, he said, firms will need to demonstrate that the interactions they implement lead to fair outcomes for customers.
He argued this is much easier when there is a demonstrable audit trail of interactions. He referred to electronic platforms used for financing transactions, recorded conversations with clients, and electronic signature processes. In a high-volume business, he said, a paper-based model in two or three years’ time will be very difficult, not necessarily in terms of complying, but in terms of providing evidence of compliance.
Compulsory versus optional products
Arenz said there is still significant confusion among consumers about what is compulsory and what is optional in finance deals.
She said customers often do not fully appreciate that comprehensive vehicle insurance is generally part of the vehicle finance agreement. At the same time, they may not understand that they have the option of sourcing their own vehicle insurance, provided it meets the lender’s requirements.
She described a recurring pattern of complaints in which customers cancel their insurance or fail to provide proof of alternative cover, the credit provider then imposes insurance under the finance agreement, and customers later discover unexpected premium deductions and lodge complaints with the FAIS Ombud.
Arenz said these cases reveal a disconnect between what customers understood about the contractual and insurance implications of the sale and the actual terms of the agreement. She said it remains important to ensure customers understand why certain products are compulsory, what options they have and the consequences of not having the required cover.
Improving disclosures, processes, and training
On improvements in disclosures and consent, Arenz said standardised templates and generic ROAs may be more efficient in a high-volume setting, but they often lack sufficient detail about what was actually discussed, what questions or concerns the customer raised, or what limitations were explained. She recommended focusing on better-quality records and giving customers information before finalising the transaction, so they can review documents and prepare questions. This, she said, enhances transparency and complements the advice process.
When everything happens in the moment, amid the excitement of purchase, she said customers may not fully grasp the implications. She observed that complaints tend to arise around limitations rather than benefits and said financial advice is intended to support informed and appropriate decision-making; when that purpose is lost, complaints tend to follow.
Asked about best practices for elevating F&I standards, Marx said representatives must be fit and proper under FAIS, and that product knowledge and ongoing product training are very important. She pointed to the continuous professional development requirement and said CPD should be relevant to the motor industry.
She also noted the importance of electronic processes, saying F&I managers cannot function if dealer management systems or sanction-screening tools are not working, because this halts process flow, delays deliveries, and causes bottlenecks, which in turn reduce the time available for interaction with the customer. She said a manual process would create risk and hinder sales.
Marx urged F&I managers to raise uncertainties with key individuals and compliance officers instead of making up product knowledge, warning that the latter leads to advice that can result in complaints and damage to product brands.
She recommended scenario-based training, such as demonstrations of how to sell warranties or credit life, and said senior staff have an obligation to ensure that younger entrants understand the ethical side of the business, including honesty and integrity, which she linked to fewer complaints and less negative attention on the motor trade.
Oversight, complaints data, and the cost of non-compliance
Arenz said oversight should extend beyond checking that documentation has been signed and should include the use of complaints data to monitor trends and root causes, as well as reviews of call recordings and quality-assurance processes.
She recommended ongoing training for F&I agents on product features, communication, conduct risk, and fair consumer outcomes, and suggested that firms periodically assess whether their sales and documentation processes are unintentionally creating conduct risk by becoming overly transactional or procedural.
Seyffert said the cost of non-compliance far exceeds the cost of compliance. He referred to liability and regulatory sanctions as potential consequences of non-compliance and noted that the last interaction in a dealership is often with the F&I manager. That interaction, he said, is the impression that stays with the client, and if it is positive and professional, the dealership is more likely to gain a return customer.





