Project Overview
A UK FCA-authorised mortgage broker with 240 advisers and 8,400 active clients wanted to build a digital mortg...
Technology Stack
Compliance & Standards
The Challenge
A UK FCA-authorised mortgage broker with 240 advisers and 8,400 active clients wanted to build a digital mortgage broker platform — replacing manual fact-finding (paper, Excel) with a digital client journey incorporating Open Banking affordability verification, automated sourcing (criteria matching across 90 lenders), and digital document submission. FCA MCOB (mortgage conduct of business), FCA Consumer Duty PS22/9, ICO UK GDPR for mortgage data, and FCA Suitability Assessment records were the requirements. Budget: £120,000.
Our Approach
TrueLayer AISP
12-month bank statement analysis for income verification and expenditure categorisation.
Income verification
salary credits → employer verification (HMRC PAYE reference cross-check), rental income, dividend income, and benefits income identified.
Expenditure categorisation
committed (mortgage/rent, loans), basic (utilities, food), discretionary (entertainment, subscriptions), and irregular (annual costs).
Affordability calculation
lender-specific affordability model applied (each lender has different stress test — ONS expenditure benchmarks for declared vs undeclared expenditure).
Mortgage Criteria Sourcing Engine
90-lender criteria database: each lender's criteria (LTV limits, income multiples, property types, credit history requirements) stored as structured rules.
Criteria matching
client profile → filtered lender list → ranked by rate (APRC).
Integration with Twenty7Tec/Trigold criteria engine
real-time rate and criteria data.
Suitability filtering
- products automatically filtered by FCA MCOB suitability (repayment type, term, rate type appropriate to client needs).
- FCA MCOB Digital Fact-
Find and Suitability
MCOB 4.7
A Mortgage Illustrations
ESIS generated automatically from criteria match → adviser reviews before client presentation.
Suitability Report
digital suitability assessment (client objectives, needs, circumstances, product recommendation justification) — generated from structured fact-find data.
MCOB 11 Responsible Lending
affordability assessment documented and stored (FCA audit trail).
Digital signatures
client signs Mortgage Application Agreement (MAA) via DocuSign.
Lender document portals
90 different portals, 90 different document formats.
ClickMasters solution
- document submission API layer abstraction — single submission from broker platform → correct format transformation → lender portal API (where available) or automated email (where no API).
- Decision in Principle (DIP): automated DIP submission for supporting lenders (Nationwide, Halifax, Santander API).
DIP turnaround
automated DIP within 30 seconds for API-connected lenders (previously 2–3 days manual submission and wait).
The Results
Platform live at 20 weeks, £112,000 — under budget.
Fact-find completion time: 2.8 hours → 45 minutes.
Affordability calculation: manual 4-hour exercise → automated 8 minutes.
DIP turnaround (API lenders): 2–3 days → 30 seconds.
MCOB suitability report: automated → 78% accepted without adviser amendment.
Consumer Duty value assessment: confirmed by FCA compliance review.
Adviser satisfaction: 4.6/5 (legacy paper process: 1.9/5).
“30-second DIP versus 2–3 days. Adviser satisfaction from 1.9 to 4.6. Fact-find 2.8 hours to 45 minutes. 78% suitability reports accepted without amendment — the structured data generates better first drafts than manual writing. FCA Consumer Duty review confirmed compliant. The advisers genuinely celebrate using this platform." — Managing Director, UK Digital Mortgage Broker (name withheld)”
Project Details
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