Project Overview
A UK mutual building society with £4.2B mortgage book and 28,000 members wanted to build a digital mortgage pl...
Technology Stack
Compliance & Standards
The Challenge
A UK mutual building society with £4.2B mortgage book and 28,000 members wanted to build a digital mortgage platform — replacing paper-based applications with a fully digital mortgage application, automated underwriting decision, and digital mortgage offer. FCA MCOB (Mortgage Conduct of Business), FCA Consumer Duty PS22/9, Mortgage Credit Directive (MCD), FCA ICOBS (buildings insurance), Equifax/Experian credit decision, and HM Land Registry HMLR integration were the requirements. Budget: £180,000.
Our Approach
MCOB 4
mortgage illustration (ESIS — European Standardised Information Sheet) presented before application, in prescribed format.
MCOB 6
mortgage offer in prescribed format with 7-day reflection period.
MCOB 11
responsible lending — affordability assessment documented and audit-trailed.
Digital application
property details (OS Places API UPRN), employment income (Open Banking AISP verification), expenditure (ONS expenditure benchmarks), and existing credit (soft credit search — Equifax).
Automated underwriting decision
loan-to-value (LTV) calculation (valuation API — Rightmove AVM / e.surv AVM), income-to-mortgage multiplier, credit score threshold (Equifax Mortgage Score), and adverse credit check (CCJs, IVAs, bankruptcy — Companies House + HMRC).
Decision outcomes
auto-approve (meets all criteria), refer (borderline — underwriter review), auto-decline (fails hard criteria).
FCA MCOB
auto-decline reasons provided in plain English — not codes.
HMLR Business Gateway
automated property data enrichment (title register, proprietorship details, charges/mortgages registered against property).
Automated checks
existing charge on property (competing mortgage), title type (freehold vs leasehold — leasehold minimum term check), and flood risk zone (OS National Flood Risk Assessment API).
Title insurance
automated Defective Title Insurance API quotation if title defects detected.
Consumer Duty Consumer Understanding
jargon eliminated from all mortgage documentation.
Affordability calculator
plain English — "Based on your income of £X, we could lend up to £Y."
Rate comparison
total cost of credit displayed prominently (not just monthly payment).
FCA Consumer Duty Vulnerable Customer
financial difficulty indicator in application (long-term illness, recently unemployed, bereavement) — triggers enhanced support pathway not standard automated underwriting.
The Results
Platform live at 22 weeks, £168,000 — under budget.
Digital application completion rate: 74% (industry benchmark: 55%).
Auto-approve rate: 62% (remaining 38% referred to underwriter).
Average decision time: 4.2 days (paper) → 18 minutes (auto-approve) / 3.1 days (referral).
FCA MCOB audit: mortgage offer documentation reviewed and confirmed compliant.
Consumer Duty review: zero adverse findings.
HMLR integration: 98.4% successful title retrieval first attempt.
Member satisfaction: 4.5/5.
“74% digital application completion versus 55% industry benchmark. 18-minute decision for auto-approvals versus 4.2 days on paper. The Consumer Duty vulnerable customer pathway was the feature our board was most concerned about — zero adverse findings on the FCA review. HMLR 98.4% title retrieval — the paper process had 23% requiring manual chase." — Chief Commercial Officer, UK Building Society (name withheld)”
Project Details
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