Project Overview
A UK FCA-authorised challenger bank serving 28,000 SME clients wanted to build a cashflow forecasting platform...
Technology Stack
Compliance & Standards
The Challenge
A UK FCA-authorised challenger bank serving 28,000 SME clients wanted to build a cashflow forecasting platform — using Open Banking transaction data, invoice data, and payroll data to provide 13-week rolling cashflow forecasts. FCA Consumer Duty (SME banking is not Consumer Duty for micro-businesses, but the bank extended it voluntarily), UK GDPR for SME financial data, PSD2 AISP data sharing, and HMRC Making Tax Digital (MTD) data integration were the requirements. Budget: £100,000.
Our Approach
TrueLayer AISP
business current account, business savings, business credit card transactions (12 months history, daily refresh).
HMRC MTD VAT API
VAT return history (quarterly liability) as a proxy for business revenue pattern.
Xero/QuickBooks API
invoice data (open invoices as receivables, supplier invoices as payables).
Data normalisation
all data sources normalised to a weekly cashflow category taxonomy (receipts, payroll, HMRC, supplier payments, bank charges, other). 13-
Forecasting methodology
category-specific algorithms.
Payroll
fixed (known amount and date from payroll data).
PAYE/NI
calculated from payroll data (employer NI + PAYE liability).
VAT
quarterly from MTD return history, smoothed to monthly accrual.
Sales receipts
ML model (LSTM sequence model in PyTorch) trained on 18 months of transaction history — learns business-specific payment timing patterns.
Supplier payments
invoice due dates from Xero/QuickBooks.
Stress test scenarios
what if largest customer is 30 days late? what if three invoices are disputed simultaneously? what if VAT is due in this period?
Each stress scenario
recalculates 13-week forecast with scenario applied, shows minimum cashflow week, and flags if balance drops below a configurable safety threshold.
Alert
- if forecast shows negative cashflow in any week within 4 weeks, bank sends in-app notification to SME owner.
- FCA Consumer Duty (Voluntary Extension): The bank voluntarily applied FCA Consumer Duty principles to all SME clients.
Consumer Support
cashflow alert triggers proactive outreach from SME relationship manager.
Consumer Understanding
forecast explanations in plain English ("Your lowest cashflow week is forecast for 14–20 March because your VAT payment is due and your two largest invoices are not expected to be paid until after that date").
Products and Services
credit facility upsell only surfaced when cashflow forecast shows genuine stress.
The Results
Platform live at 14 weeks, £92,000 — under budget.
SME engagement: 68% of enrolled SMEs checking forecast weekly (industry benchmark: 20% weekly app engagement).
Early cashflow stress alerts: 340 SMEs received alerts in first 6 months — 87% accessed credit facility or took action before reaching negative cashflow.
SME churn: 18% reduction in SME accounts closed.
Consumer Duty voluntary review: bank's voluntary Consumer Duty application to SMEs cited as industry best practice by FCA Innovation team.
“340 SME early warnings in 6 months — 87% of them acted before reaching negative cashflow. That is the product. Without the forecast, they would not have known until their bank account was empty. The FCA Innovation team cited our voluntary Consumer Duty extension as industry best practice. That is a better outcome than we expected." — Chief Product Officer, UK Challenger Bank (name withheld)”
Project Details
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