Project Overview
A UK FinTech startup had received FCA authorisation as an e-money institution and wanted to build a consumer s...
Technology Stack
Compliance & Standards
The Challenge
A UK FinTech startup had received FCA authorisation as an e-money institution and wanted to build a consumer savings platform — aggregating savings accounts from partner banks using Open Banking (AISP), providing savings goal tracking, automatic round-up saving, and instant access to partner bank accounts via the platform. The core technical challenge: FCA COBS disclosure requirements for multi-provider product comparisons, UK GDPR consent management for Open Banking data processing, and FCA Consumer Duty evidencing. Budget: £110,000.
Our Approach
Open Banking AISP Integration: TrueLayer as Open Banking provider. Multi-bank account aggregation: Barclays, HSBC, Lloyds, Monzo, Starling, Nationwide. Consent management: 90-day re-authorisation (PSD2 requirement), granular consent per bank per account. Transaction enrichment (merchant categorisation) for savings opportunity identification. FCA Consumer Duty Architecture: Product comparison disclosure: FCA COBS 4 requires fair, clear, not misleading communication. Partner bank savings rates displayed with full FSCS (Financial Services Compensation Scheme) protection status. APY (Annual Percentage Yield) calculations standardised across providers. Decision audit trail per user recommendation. Round-Up Saving: Automated round-up from connected current accounts: transaction detected via Open Banking webhook, round-up amount calculated, queued for end-of-day sweep to designated savings account via Faster Payments. UK GDPR basis: legitimate interest (savings management service). Notification and Engagement: GOV.UK Notify for regulatory communications (account statements, rate changes). FCM/APNs push notifications for savings milestones. PECR consent for marketing push notifications (separate from transactional notifications).
The Results
Launched at 14 weeks, £104,000 — under budget. 6,200 registered users in first 3 months. Open Banking: 4.2 banks connected per active user. Round-up: average £47/month saved automatically per user. FCA Consumer Duty audit at 6 months: zero adverse findings. FSCS coverage clearly displayed: 94% of users correctly identified which partner protects their savings (FCA metric). Series A conversations at month 5.
“The Open Banking consent management was the most complex part — keeping track of which users have consented to which accounts, re-authorisation at 90 days, granular revocation. ClickMasters built it correctly and the FCA loved the audit trail." — CEO, UK FinTech Savings Platform (name withheld)”
Project Details
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