How do lenders make AI compliant with CCA/CONC and Consumer Duty?
CCA/CONC and Consumer Duty AI compliance are architected — a policy layer encoding the rules, retrieval scoped to approved sources, evaluations that continuously score outcomes, and a Consumer-Duty overlay that captures outcome-quality signals for every AI-touched interaction. Firms building on this shape ship new automations in weeks; firms without it die at compliance review.
CCA/CONC and Consumer Duty AI compliance are architected — a policy layer encoding the rules, retrieval scoped to approved sources, evaluations that continuously score outcomes, and a Consumer-Duty overlay that captures outcome-quality signals for every AI-touched interaction. Firms building on this shape ship new automations in weeks; firms without it die at compliance review.
The four-layer envelope for lenders
Same three-layer architecture (policy, retrieval, evals) as the FCA guide, plus a fourth Consumer-Duty overlay specifically for borrower-facing outcomes. This is the architecture that survives supervisory scrutiny.
The Consumer-Duty overlay contents
- Per-interaction outcome capture (understanding, action, harm).
- Vulnerability signal detection and evidenced routing.
- Segment-level outcome dashboards visible to the SMF holder.
- Automatic escalation on outcome-anomaly patterns.
- Audit-loggable trail from decision to outcome per borrower.
Related questions
SMF ownership of AI?
Named SMF per system, documented in the policy layer.
Does the FCA have specific AI lender rules?
Not a standalone rulebook; CCA, CONC, Consumer Duty and SM&CR all apply and the architecture maps to all of them.
Consumer Duty for existing customers?
Yes — the overlay applies to servicing, collections and communications, not only to origination.
Auditor comfort?
Auditors see the governance package, evals, and outcome dashboards. This is a normal conversation.
Timeline?
The envelope is designed inside the £15k Diagnostic; live in production over the first Build engagement.
The AI-first lenders are pulling away on unit economics, not on rate. Every quarter you defer the architecture is a quarter of compounding disadvantage.
The £15k AI Diagnostic maps your lender stack, prioritises the systems that pay back fastest and produces a costed sequenced build plan.