FinTech SME Working Capital Platform — UK Alternative Lender

Automated Credit Decisioning Engine: Credit decision framework: CCJ/IVA/bankruptcy check (Experian Commercial), credit score (Experian Commercial Score 0–100), financial performance (Open Banking AISP — 12 months bank statement analysis), trading history (Companies House — date of incorporation, filing history, accounts), and industry risk (Companies House SIC code → industry risk score). Decision outcomes: auto-approve (meets all criteria, instant offer), refer (borderline — underwriter review within 4 hours), auto-decline (fails hard criteria with CONC 7 decline reason provided). Invoice Verification and Fraud Prevention: Invoice financing: SME submits invoice (PDF) → OCR extraction (Google Cloud Vision — merchant, amount, VAT, invoice date) → debtors ledger check (cross-reference against existing invoices — duplicate detection) → debtor creditworthiness (Experian Business) → funding offer. Fraud prevention: invoice verification webhook — call debtor to confirm invoice authentic before funding (for invoices > £10,000). Concentration limit: maximum 25% of facility to a single debtor — automatic enforcement. HMRC RTI Payroll Data Integration: HMRC Real Time Information (RTI) access for credit assessment: HMRC Business Tax Account API — SME consents to HMRC sharing their RTI payroll data with the lender. RTI data: number of employees, total PAYE liability, payment history (PAYE paid on time or late). Credit assessment use: PAYE arrears is a leading indicator of financial distress — integrated into credit score weighting. HMRC consent: SME authorises HMRC data sharing at application (OAuth 2.0 — separate Government Gateway consent). FCA CONC Credit Agreement Automation: FCA CONC: regulated credit agreements for SME lending. Pre-contract information (Pre-Contract Credit Information — PCCI) presented before agreement execution. Regulated credit agreement: digital agreement (DocuSign eSignature), CONC-required terms (APR prominently displayed, total charge for credit, right to withdraw). FCA Consumer Duty: for credit products, value assessment required — cost of credit vs benchmark (FCA CONC rate cap for small business lending where applicable).