FCA Handbook - CONRED 5.9 Consumer redress scheme: information requirements

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CONRED 5.9 Consumer redress scheme: information requirements

Requests for information by the FCA

In relation to any matter concerning or relating to the scheme, section 165 (Regulator’s power to require information: authorised persons etc.) of the Act, and any provision of Part XI (Information Gathering and Investigations) of the Act which relates to that section, apply to any firm and any successor which is an unauthorised person as if it were an authorised person.

Early start reporting requirements

A lender must notify the FCA of its intention to implement any of the scheme steps during the implementation period, see CONRED 5.2.1R. The content of that notification is set out in the following rules.

A lender must, within 15 working days of the scheme effective date, notify the FCA:

(1) if it intends to implement any of the scheme steps during the implementation period; and
(2) of the name of the senior manager (or equivalent where there is no senior manager) responsible for oversight and overall delivery of the scheme and contact details (‘senior manager responsible’).

(1) A lender must provide the information in (2) if, under CONRED 5.2.1R, the lender intends to implement any of the scheme steps before the end of the implementation period.
(2) The information is:
1. (a) the date the lender intends to begin processing scheme cases under CONRED 5.2.1R;
2. (b) the one-off information set out in CONRED 5.9.6R;
3. (c) a scheme implementation plan that contains the information set out in CONRED 5.9.7R; and
4. (d) a forecast report that contains the information set out in CONRED 5.9.9R.
(3) The information must be provided no later than 15 working days before the lender begins identifying scheme cases in accordance with the first and second scheme steps (as set out in CONRED 5.2.9R to CONRED 5.2.17R).

(1) If a lender begins identifying scheme cases in accordance with the first and second steps (as set out in CONRED 5.2.9R to CONRED 5.2.17R) before the end of the implementation period, CONRED 5.9.11R to CONRED 5.9.23R apply with the modification in (2).
(2) In CONRED 5.9.11R and CONRED 5.9.13R, the reference to ‘the end of the implementation period’ must be substituted with ‘the date on which the lender began processing scheme cases under CONRED 5.2’.

One-off information requirement

A lender must, within 6 weeks of the scheme effective date, provide the FCA with the following one-off information:

(1) the number of motor finance agreements in the lender’s starting population, identified in accordance with CONRED 5.1.6R;
(2) the number of complaints relating to motor finance agreements received by the lender prior to the scheme effective date;
(3) the number of complaints in (2) where complainants are represented by a professional representative, such as a claims management company or a solicitor;
(4) the number of complaints in (2) where complainants are represented by multiple professional representatives, such as a claims management company or a solicitor; and
(5) attestations from the senior manager responsible, confirming that the lender has the systems and controls to:
1. (a) successfully identify the starting population of potentially impacted customers in accordance with the first and second steps set out in CONRED 5.2.9R to CONRED 5.2.17R;
2. (b) identify which of its own records and information are relevant assessing motor finance agreements, as required by this chapter; and
3. (c) take the steps under the scheme to obtain relevant records and information required to assess motor finance agreements from third parties where these are not held by the lender.

Scheme implementation plan

(1) A lender must provide a scheme implementation plan to the FCA at the same time as it provides the FCA with the one-off information set out in CONRED 5.9.6R.
(2) A scheme implementation plan must include:
1. (a) a lender’s plan for complying with its obligations under the scheme; and
2. (b) a lender’s policies and procedures addressing the lender’s approach to the matters in (3).
(3) The matters referred to in (2)(b) are:
1. (a) data collection, including:
  1. (i) the circumstances in which the lender will contact brokers; and
  2. (ii) the name and firm reference number of each broker the lender will contact;
2. (b) the grouping of cases and approach to making cohort or group-based decisions about:
  1. (i) cases which fall outside the subject matter of the scheme;
  2. (ii) identifying cases the lender considers to be time-barred and excluded from the definition of scheme case under CONRED 5.1.17R(1)(g);
  3. (iii) identifying relevant arrangements at the first and second scheme steps;
  4. (iv) identifying cases at the first and second scheme steps that are exceptions pursuant to CONRED 5.2.20R for captive and white label relationships;
  5. (v) using rebuttals at stage 1 of the third scheme step, under CONRED 5.3.14R and at stage 2 of the third scheme step under CONRED 5.3.22R; and
  6. (vi) issuing full and final early settlement offers at any stage of the scheme under CONRED 5.2.7R(1) if a lender is likely to make such offers;
3. (c) the build and use of automated processes, including for:
  1. (i) decision-making tools;
  2. (ii) redress calculators; and
  3. (iii) making payments to consumers;
4. (d) the use of outsourcing arrangements, including the name of the outsourcer, if applicable;
5. (e) the quality assurance of cases being processed under the scheme and their outcomes;
6. (f) preventing and detecting scams, including the approach to identifying and verifying a consumer’s identity; and
7. (g) consumers with multiple professional representatives, such as a claims management company or a solicitor.
(4) The scheme implementation plan must set out whether the lender intends to apply for a waiver, including an intention to request for an extension of time to complete any steps under the scheme.
(5) If, following the submission of the scheme implementation plan to the FCA, the lender materially changes or updates its approach to any of the areas in (3) or (4) so that the scheme implementation plan is no longer accurate, the lender must promptly notify the FCA and provide details of its updated approach.

Forecast report

(1) The FCA requires lenders to provide a report which forecasts how they expect to assess motor finance agreements and process scheme cases under the scheme, including a breakdown of the number of cases a lender expects to process each month, until the lender reaches the end of the scheme.
(2) The forecast report is to be provided to the FCA at the 6-week point, alongside the one-off information and scheme implementation plan, and then an updated forecast report should be provided every 3 months from then.
(3) The forecast report data should be reported separately for consumers who have complained, and consumers who have not complained, where this is applicable to the reported metric. The forecast report data should also be broken down by type and combination of relevant arrangement, where this is indicated in the provision.

(1) A lender must report a delivery forecast to the FCA (a ‘forecast report’) in accordance with this rule.
(2) The forecast report must contain the following information:
1. (a) a monthly forecast of the number of motor finance agreements (by type of relevant arrangement, see CONRED 5.9.23R) to be processed each month, until all motor finance agreements that the lender must process have reached the end of the scheme;
2. (b) the number of motor finance agreements in the lender’s starting population, identified in accordance with CONRED 5.1.6R;
3. (c) of the number reported in (b), the number of full and final early settlement offers in accordance with CONRED 5.2.7R(1) that the lender forecasts issuing;
4. (d) of the number reported in (b), the number of motor finance agreements that the lender forecasts will be excluded from being a scheme case under CONRED 5.1.17R(1)(d), for exceeding the total amount of credit set out in CONRED 5.1.18R;
5. (e) of the number reported in (b), the number of motor finance agreements that the lender forecasts will be time-barred pursuant to CONRED 5.1.17R(1)(g);
6. (f) of the number reported in (b), the number of agreements that the lender forecasts will satisfy the conditions of a scheme case set out in CONRED 5.1.17R;
7. (g) of the number reported in (f), the number of scheme cases that the lender forecasts have one or more relevant arrangements (by type of relevant arrangement, see CONRED 5.9.23R);
8. (h) of the number reported in (g), the number of cases (by type of relevant arrangement, see CONRED 5.9.23R) where the lender intends to rely on:
  1. (i) the exception for captive and white label relationships at the first and second scheme steps, set out in CONRED 5.2.20R;
  2. (ii) CONRED 5.3.14R to rebut the presumption of unfairness at stage 1 of the third scheme step; or
  3. (iii) CONRED 5.3.22R to rebut the presumption of loss or damage at stage 2 of the third scheme step;
9. (i) of the number reported in (g), the number of cases (by type of relevant arrangement, see CONRED 5.9.23R) that the lender forecasts will proceed to a redress calculation in accordance with the fourth scheme step;
10. (j) of the number reported in (i), the number of cases (by type of relevant arrangement, see CONRED 5.9.23R):
  1. (i) where the lender forecasts that the consumer will be sent a redress determination of £0 in accordance with CONRED 5.4.6R (where the consumer paid a minimal cost of credit, offered to 5% of the market at the time); and
  2. (ii) where the lender forecasts that the consumer will be sent a redress determination greater than £0 in accordance with scheme rules.
11. (k) the lender’s cash flow forecast for:
  1. (i) redress payments under (2)(j); and
  2. (ii) early settlement payments under (2)(c).
(3) The information in (2)(a) to (k) should, as applicable, be separately reported for the number of cases involving a complaint, regardless of whether the complaint was received before or after the scheme effective date.
(4) A forecast report must be sent to the FCA:
1. (a) within 6 weeks of the scheme effective date; and
2. (b) every 3 months thereafter until all motor finance agreements that the lender must process have reached the end of the scheme.

Baseline monthly report

(1) The FCA requires lenders to provide a monthly report which sets out the actual number of motor finance agreements assessed, and scheme cases processed, at each scheme step, for every relevant month, under the same headings as the forecast report. The report must be provided on a monthly basis until the lender has processed all cases under the scheme.
(2) The purpose of this monthly report is for the FCA to compare actual processing of agreements under the scheme to the lenders’ forecasts. This monthly report must mirror the forecast report in order for this comparison to be made.

(1) A lender must provide a baseline monthly report that comprises the information required in CONRED 5.9.9R(2) within one month of the end of the implementation period.
(2) The information reported in the baseline monthly report pursuant to CONRED 5.9.9R(2) should be the actual number of motor finance agreements assessed, and scheme cases processed under the scheme, not forecasts or estimates.
(3) The information in the baseline monthly report must be for the month prior to the month in which it is being submitted.
(4) The information in the baseline monthly report should, as applicable, be separately reported for the number of cases involving a complaint, regardless of whether the complaint was received before or after the scheme effective date.
(5) The baseline monthly report must be submitted to the FCA:
1. (a) each month no later than one month after the previous baseline monthly report was submitted to the FCA; and
2. (b) until such time as the lender has completed the scheme steps as set out in this chapter in respect of its entire population of scheme cases.

Detailed monthly report

(1) The FCA requires lenders to provide a detailed monthly report alongside the baseline monthly report. The detailed report provides additional information that the lender is not required to forecast, and so not already included in the baseline monthly report.
(2) The monthly data should be reported separately for consumers who have complained, and consumers who have not complained, where this is applicable to the reported metric. The monthly data should also be broken down by type and combination of relevant arrangement, where this is indicated in the provision.
(3) The lender needs to provide all the information described in CONRED 5.9.14R to CONRED 5.9.20R where this information becomes available to the lender as cases are processed through the scheme.

(1) A lender must provide a detailed monthly report that comprises the information required in CONRED 5.9.14R to CONRED 5.9.20R, within one month of the end of the implementation period.
(2) The information in the detailed monthly report must be for the month prior to the month in which it is being submitted.
(3) The information in the detailed monthly report should, as applicable, be separately reported for the number of cases involving a complaint, regardless of whether the complaint was received before or after the scheme effective date.
(4) The detailed monthly report must be submitted to the FCA:
1. (a) each month no later than one month after the previous detailed monthly report was submitted to the FCA; and
2. (b) until such time as the lender has completed the scheme steps as set out in this chapter in respect of its entire population of scheme cases.

The detailed monthly report must include the following information in relation to consumer decision-making:

(1) the number of cases where:
1. (a) a consumer was invited to opt in to the scheme at the second scheme step (in accordance with CONRED 5.2.11R);
2. (b) of the number in (a), the number of scheme cases where a consumer did not opt in within the 6-month deadline set out in CONRED 5.2.11R(2)(c)(ii); and
3. (c) of the number in (a), the number of scheme cases where a consumer did opt in to the scheme (within the 6-month deadline);
(2) in relation to all motor finance agreements that must be assessed by the lender:
1. (a) the number of agreements in respect of which the lender sent a provisional redress decision at any step of the scheme;
2. (b) of the number in (a), the number accepted by a consumer, including:
  1. (i) the number of decisions that were accepted by a consumer represented by at least one professional representative, such as a claims management company or a solicitor; and
  2. (ii) the number of decisions that were accepted by a consumer not represented by a professional representative, such as a claims management company or a solicitor;
(c) of the number in (a), the number objected to by a consumer, including:
1. (i) the number of decisions that were objected to by a consumer represented by at least one professional representative, such as a claims management company or a solicitor; and
2. (ii) the number of decisions that were objected to by a consumer not represented by a professional representative, such as a claims management company or a solicitor
(d) of the number in (a), the number of which that were responded to by a consumer, confirming they wished to opt-out of the scheme, including:
1. (i) the number of consumers represented by at least one professional representative, such as a claims management company or a solicitor, who wished to opt-out; and
2. (ii) the number of consumers not represented by a professional representative, such as a claims management company or a solicitor, who wished to opt-out;

(3) in relation to the number of full and final early settlement offers issued by the lender at any stage of the scheme (as reported in the baseline monthly report), the number of offers which were:
1. (a) accepted by a consumer, including:
  1. (i) the number of acceptances by a consumer represented by at least one professional representative, such as a claims management company or a solicitor; and
  2. (ii) the number of acceptances by a consumer not represented by a professional representative, such as a claims management company or a solicitor;
2. (b) rejected by a consumer, including:
  1. (i) the number of rejections by a consumer represented by at least one professional representative, such as a claims management company or a solicitor; and
  2. (ii) the number of rejections by a consumer not represented by a professional representative, such as a claims management company or a solicitor;
(4) in relation to the number of redress determinations sent by the lender at any step of the scheme, the number which were:
1. (a) accepted by a consumer, including:
  1. (i) the number of acceptances by a consumer represented by at least one professional representative, such as a claims management company or a solicitor; and
  2. (ii) the number of acceptances by a consumer not represented by a professional representative, such as a claims management company or a solicitor;
2. (b) rejected by a consumer, including:
  1. (i) the number of rejections by a consumer represented by at least one professional representative, such as a claims management company or a solicitor; and
  2. (ii) the number of rejections by a consumer not represented by a professional representative, such as a claims management company or a solicitor.

The detailed monthly report must include, in relation to credit brokers and in relation to all motor finance agreements that the lender must assess, the number of agreements in respect of which:

(1) the lender requested relevant records and information from a credit broker (in accordance with CONRED 5.2.25R and CONRED 5.3.4R);
(2) the credit broker did not respond before the deadline of 1 month (in accordance with CONRED 5.2.28R and CONRED 5.3.6R);
(3) the lender sent a further request for relevant records and information from a credit broker (in accordance with CONRED 5.2.27R and CONRED 5.3.5R);
(4) the credit broker did not respond before the 14-day deadline (in accordance with CONRED 5.2.27R and CONRED 5.3.5R);
(5) the lender relied on the insufficient information provisions in CONRED 5.2.13R before sending a provisional redress decision stating that no redress was due.

The detailed monthly report must include the following information in relation to complaints and professional representatives, such as a claims management company or a solicitor:

(1) As of the date on which the lender starts to assess motor finance agreements in accordance with the first scheme step set out in CONRED 5.2.9R, the number of complaints:
1. (a) in relation to which the consumer is represented by either:
  1. (i) a claims management company or a solicitor; or
  2. (ii) multiple professional representatives (including a claims management company and a solicitor);
2. (b) where a final response has not been issued by the lender; and
3. (c) that have been referred to the Financial Ombudsman Service and which the Financial Ombudsman Service has:
  1. (i) upheld; and
  2. (ii) rejected.
(2) After the lender has completed the first and second scheme steps pursuant to CONRED 5.2.9R and CONRED 5.2.11R, the number of scheme cases (as reported in the baseline monthly report) where the consumer is represented by either:
1. (a) a claims management company or a solicitor; or
2. (b) multiple professional representatives (including a claims management company and a solicitor).

The detailed monthly report must include the following information in relation to redress:

(1) in relation to all motor finance agreements which are determined to be scheme cases at the first and second scheme steps pursuant to CONRED 5.2.9R and CONRED 5.2.11R:
1. (a) the number of provisional redress decisions issued (in accordance with CONRED 5.2.9R(2)(e)(i) where the consumer obtained no redress because the lender did not identify a relevant arrangement;
2. (b) the number of scheme cases where one of the following relevant arrangement exceptions applied:
  1. (i) the total amount of commission was £150 or less, as set out in CONRED 5.2.19R(2)(a);
  2. (ii) the annual percentage rate for the motor finance agreement was 0%, as set out in CONRED 5.2.19R(2)(b);
  3. (iii) in relation to a discretionary commission arrangement, the interest rate that applied under the motor finance agreement was the lowest rate of interest in the range of interest rates that could have been selected by the credit broker, as set out in CONRED 5.2.19R(3); and
  4. (iv) in relation to a tied arrangement, the exception for captive and white label relationships described in CONRED 5.2.20R applied;
(2) in relation to all scheme cases which proceed to the third scheme step in CONRED 5.3.1R:
1. (a) the number of provisional redress decisions issued under CONRED 5.3.20R(2)(a) where the lender determined there was not an unfair relationship in accordance with CONRED 5.3.1R(1) because:
  1. (i) there was adequate disclosure as described in CONRED 5.3.10R (by type of relevant arrangement, see CONRED 5.9.23R);
  2. (ii) the lender applied the consumer knowledge rebuttal set out in CONRED 5.3.14R(1); or
  3. (iii) the lender applied the unused tie rebuttal set out in CONRED 5.3.14R(2);
2. (b) in relation to (2)(a), the number of provisional redress decisions where the consumer has objected to the decision within 1 month;
3. (c) in relation to (2)(b), the number of cases where the lender accepted the consumer’s objection and proceeded to the next stage or step in the scheme pursuant to CONRED 5.3.27R(6);
4. (d) the number of provisional redress decisions issued under CONRED 5.3.26R(2)(a) where the lender determined that the unfair relationship did not cause loss or damage to the consumer because the presumption was rebutted in accordance with CONRED 5.3.22R(1);
5. (e) in relation to (2)(d), the number of provisional redress decisions where the consumer has objected to the decision within 1 month;
6. (f) in relation to (2)(e), the number of cases where the lender accepted the consumer’s objection and proceeded to the next stage or step in the scheme pursuant to CONRED 5.3.27R(6);
(3) in relation to all scheme cases which proceed to the fourth and fifth scheme steps in CONRED 5.4:
1. (a) the number of provisional redress decisions issued under CONRED 5.4.36R(2) where the lender calculated the redress payable to the consumer:
  1. (i) using the commission repayment remedy methodology set out in CONRED 5.4.4R; or
  2. (ii) using the hybrid remedy methodology set out in CONRED 5.4.22R;
2. (b) of the number reported for (3)(a)(ii), the number of decisions where redress has been capped under:
  1. (i) the adjusted commission plus interest cap, as set out in CONRED 5.4.19R;
  2. (ii) the adjusted realised cost of credit cap, as set out in CONRED 5.4.20R; or
  3. (iii) the total cost of credit cap, as set out in CONRED 5.4.21R;
(4) the total number of redress determinations issued by the lender at any step of the scheme;
(5) of the number reported for (4), the number of redress determinations (by type of relevant arrangement, see CONRED 5.9.23R) issued where the lender made no offer of redress;
(6) of the number reported for (4), the number of redress determinations which were referred to the Financial Ombudsman Service and which the Financial Ombudsman Service:
1. (a) rejected; or
2. (b) upheld;
(7) the total value of redress paid:
1. (a) under this chapter, within 1 month of the acceptance of the redress determination, in accordance with deadline for payment in CONRED 5.4.38R(3);
2. (b) under this chapter, outside of the 1-month deadline referred to in (7)(a); or
3. (c) following an award by the Financial Ombudsman Service
(8) the total value of redress offered by the lender but not accepted by the consumer.

The detailed monthly report must also include the following information in relation to financial resources:

(1) the value of redress not paid yet;
(2) the total liquid assets held (cash and cash equivalent);
(3) the net assets (or liability) position;
(4) a 3-month forecast of the total liquid assets held (cash and cash equivalent); and
(5) the amount of redress due that has neither been paid out nor provisioned for.

The rule in CONRED 5.9.18R does not apply to a dual-regulated firm.

The detailed monthly report must also include the following information in relation to timeliness:

(1) the number of provisional redress decisions (sent in accordance with CONRED 5.3.20R(2)(a) and CONRED 5.3.26R(2)(a)) that were issued:
1. (a) within 4 weeks of starting the third scheme step; and
2. (b) within 6 weeks of starting the third scheme step;
(2) the number of provisional redress decisions (sent in accordance with CONRED 5.4.6R(2)(a) and CONRED 5.4.36R) that were issued:
1. (a) within 4 weeks of starting the fourth scheme step; and
2. (b) within 6 weeks of starting the fourth scheme step;
(3) the number of consumer responses to provisional redress decisions that (in accordance with CONRED 5.3.27R(2), CONRED 5.3.27R(3) and CONRED 5.3.27R(4)(a)) were responded to in the third scheme step by the lender:
1. (a) within a 7-day period beginning on the day the response was received; and
2. (b) outside of the 7-day period in (3)(a), including:
  1. (i) the number of responses that were sent to a consumer represented by at least one professional representative, such as a claims management company or a solicitor; and
  2. (ii) the number of responses that were sent to a consumer not represented by a professional representative, such as a claims management company or a solicitor;
(4) the number of consumer responses to provisional redress decisions that (in accordance with CONRED 5.4.37R(2), CONRED 5.4.37R(3) and CONRED 5.4.37R(4)(a)) were responded to in the (fourth and fifth scheme steps in CONRED 5.4) by the lender:
1. (a) within a 7-day period beginning on the day the response was received; and
2. (b) outside of the 7-day period in (4)(a), including:
  1. (i) the number of responses that were sent to a consumer represented by at least one professional representative, such as a claims management company or a solicitor; and
  2. (ii) the number of responses that were sent to a consumer not represented by a professional representative, such as a claims management company or a solicitor;
(5) the number of redress determinations that (in accordance with CONRED 5.3.27R(5)(a) and CONRED 5.4.37R(5)) were:
1. (a) where the lender received further details of the consumer’s objection to the provisional redress decision:
  1. (i) issued by the lender within 2 months of the day the lender received the further details from the consumer; and
  2. (ii) issued by the lender outside of the 2-month period in (5)(a)(i), including:
    1. (A) the number of redress determinations that were issued to a consumer represented by at least one professional representative, such as a claims management company or a solicitor; and
    2. (B) the number of redress determinations that were issued to a consumer not represented by a professional representative, such as a claims management company or a solicitor.
2. (b) where the lender received no further details of the consumer’s objection within 1 month of the lender’s acknowledgement requesting further details from the consumer:
  1. (i) issued by the lender within 2 months of the date of expiry of that 1-month period; and
  2. (ii) issued by the lender outside of the 2-month period in (5)(b)(i), including:
    1. (A) the number of redress determinations that were issued to a consumer represented by at least one professional representative, such as a claims management company or a solicitor; and
    2. (B) the number of redress determinations that were issued to a consumer not represented by a professional representative, such as a claims management company or a solicitor;
(6) the number of redress determinations that (in accordance with CONRED 5.3.27R(7) and CONRED 5.4.37R(6)) were sent by the lender when the consumer did not respond to the provisional redress decision within 1 month:
1. (a) within 1 month of the expiry of that period; and
2. (b) outside of the 1-month period in (6)(a);
(7) the number of redress payments made under the scheme:
1. (a) within 1 month of the consumer’s acceptance of a redress determination (or provisional redress decision in CONRED 5.4.37R(3); and
2. (b) outside of the 1-month period in (7)(a).

Notifications and reports to the FCA

(1) CONRED 5.9.22R sets out the way in which lenders must report the information required by the rules in this section to the FCA. In most cases, all reporting must be done using the FCA’s RegData platform in response to RegData Information Requests that a lender will receive through the platform.
(2) In some limited circumstances, the FCA may request that the information required by the rules in this section be sent to the FCA by email, rather than using the method set out in CONRED 5.9.22R(2). Where this is required, the FCA will give the lender 7 days written notice.

(1) Notifications and other reports required by the rules in this section must be sent to the FCA using the method set out in (2) within the deadlines specified by the rules in this section.
(2) Subject to the exception in (3), lenders must report all information and data required by the rules in this section through the FCA’s data collection platform ‘RegData’.
(3) The FCA may require a lender to report the information and data required by the rules in this section by email, in which event the FCA would give 7 days written notice of this requirement.
(4) Lenders must ensure that the individual acting as their ‘RegData Principal User’ is:
1. (a) familiar with the reporting requirements in this section;
2. (b) monitoring incoming data reporting requests from the FCA; and
3. (c) allocating data reporting requests to the relevant individual.

[Editor’s note: This provision is under consideration and is subject to amendment.]

Where a reporting requirement in this section requires a lender to report the number of agreements ‘by type of relevant arrangement’, the lender should split the number of agreements reported into the following categories:

(1) agreements in relation to which there was a discretionary commission arrangement;
(2) agreements in relation to which there was a very high commission arrangement;
(3) agreements in relation to which there was a tied arrangement;
(4) agreements in relation to which there was a discretionary commission arrangement and a very high commission arrangement;
(5) agreements in relation to which there was a discretionary commission arrangement and a tied arrangement;
(6) agreements in relation to which there was a very high commission arrangement and a tied arrangement; and
(7) agreements in relation to which there was a discretionary commission arrangement, a very high commission arrangement and a tied arrangement.