COMPLIANCE · LENDING

Consumer Duty is a workflow problem, not a reporting problem

The FCA didn't ask for better reports. It asked for demonstrably better outcomes — and outcomes live in the day-to-day flow of lending work, not in a quarterly pack.

The trap of treating Duty as paperwork

Three years in, many lenders still run Consumer Duty as a retrospective exercise: the work happens in one set of systems, and once a quarter somebody assembles proof that it happened fairly. That model has two failure modes. It's expensive — skilled people spend days reconstructing decisions. And it's fragile — reconstruction is exactly what an examiner will probe.

Encoding the Duty into the journey

The alternative is to make the lending workflow itself produce the evidence. In practice, on Salesforce Financial Services Cloud, that looks like:

If your evidence requires a project to assemble, you don't have evidence — you have archaeology.

What this changes economically

Embedding controls costs effort once, at design time. Reconstructing evidence costs effort forever, at every review. Lenders who make the switch tell us the quarterly scramble simply disappears — the pack becomes an export, not a project.

Where to start

Pick one journey — new lending applications is usually right — and map where decisions happen against where evidence currently lives. The gap between those two maps is your Consumer Duty risk, and it's almost always closable with configuration rather than custom code.

This article relates to our Implementation & Compliance work. If it raised a question about your own programme, the conversation is free: book a consultation.
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