Project Overview
A UK FCA-authorised Debt Management Plan (DMP) provider administering 4,800 active DMPs needed to replace thei...
Technology Stack
Compliance & Standards
The Challenge
A UK FCA-authorised Debt Management Plan (DMP) provider administering 4,800 active DMPs needed to replace their legacy case management system. FCA CONC (Consumer Credit sourcebook) DMP obligations, FCA Consumer Duty four outcomes, creditor portal API integration (for automated distribution to creditors), and UK GDPR for highly sensitive financial vulnerability data were the compliance requirements. Budget: £110,000.
Our Approach
FCA CONC DMP Compliance Architecture
CONC 8.3: DMP providers must act in clients' best interests.
Platform architecture enforces
no DMP fee until creditor distribution begins (CONC 8.3.3), monthly client statement generation (CONC 8.3.9), annual review prompt (CONC 8.3.6), and client consent to any change in DMP terms.
Fair distribution
waterfall distribution algorithm (pro-rata distribution to creditors after DMP fees).
Major creditor APIs
Barclays, HSBC, Lloyds, NatWest, Capital One, MBNA (via FCA-mandated creditor data sharing standards).
Automated distribution notification
each creditor receives payment notification within 24 hours.
Creditor acknowledgement tracking
unacknowledged distributions flagged for manual follow-up.
Creditor freeze request
automated interest-free/charges-free request via creditor API at DMP setup.
FCA Consumer Duty Vulnerability Framework
UK Regulators'
Financial Lives Survey
DMP clients are a highly vulnerable population.
Consumer Duty Consumer Support
additional support channels for vulnerable clients (telephone, accessible digital formats).
Consumer Understanding
- DMP terms in plain English (Flesch >
- 65), fee disclosure clear before consent.
Vulnerability flag
clients who indicate mental health, financial abuse, or crisis circumstances — routed to specialist support caseworker.
DMP client data is among the most sensitive
debt details, income, expenditure, creditor list, payment history, and vulnerability flags.
Lawful basis
- contract performance.
- Special category (mental health vulnerability flag): explicit consent.
Access control
caseworker sees only their assigned clients.
Data minimisation
creditors receive only payment amounts and reference numbers — no client vulnerability data shared with creditors.
The Results
Platform live at 14 weeks, £102,000 — under budget.
Creditor distribution time: 5 days manual → same-day automated.
CONC 8.3 compliance: 100% of clients receiving monthly statements (was 84%).
Consumer Duty Consumer Support: 23 vulnerable clients routed to specialist caseworker in first month (previously unidentified).
FCA Consumer Duty audit: zero adverse findings.
Creditor interest freeze success rate: 94% within 30 days.
“23 vulnerable clients identified in the first month who had never been flagged under the old system. That is the Consumer Duty in action — we are now getting them the specialist support they need. The CONC compliance dashboard has removed the anxiety from every FCA visit." — Head of Compliance, UK DMP Provider (name withheld)”
Project Details
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