Project Overview
A UK FCA-authorised commercial lending platform (FCA Consumer Credit authorisation, GBP84M loan book, 2,800 SM...
Technology Stack
Compliance & Standards
The Challenge
A UK FCA-authorised commercial lending platform (FCA Consumer Credit authorisation, GBP84M loan book, 2,800 SME borrowers) needed to build a digital commercial lending platform -- digitising SME term loan origination, credit assessment, and loan management. FCA CONC (Consumer Credit sourcebook -- applicable to SME loans below GBP25,000), Business Finance Charter, HMRC MTD (VAT and Corporation Tax for SME financial health assessment), Companies House API, Open Banking TrueLayer AISP, AML MLRs 2017, UK GDPR, ISO 27001. Budget GBP120,000.
Our Approach
SME loan origination
- 1business details (Companies House API -- pre-fill company name, SIC code, incorporation date, directors),
- 2loan purpose and amount (GBP5,000-GBP250,000 -- term 12-60 months),
- 3financial data (Open Banking TrueLayer AISP -- 12 months bank statements, automated income and expense analysis),
- 4Companies House financials (filed accounts -- automated extraction of revenue, profit, net assets from Companies House iXBRL),
- 5HMRC MTD (if available -- VAT return data, Corporation Tax data -- financial health signals).
Digital journey completion
- 18 minutes average vs 4 days legacy paper application.
- Companies House pre-fill: 84.2% of applicant data pre-populated from Companies House.
Commercial lending credit assessment
- 1Open Banking analysis (12-month cash flow -- average monthly inflows, outflows, net position, volatility),
- 2Dun and Bradstreet commercial credit (D&B PAYDEX score -- payment performance of SME),
- 3Companies House adverse (CCJs, winding-up petitions, late filing -- Companies House filing history),
- 4directors adverse (personal credit check on directors -- Equifax commercial),
- 5affordability model (loan repayment vs monthly net cash flow -- debt service coverage ratio).
ML credit model
XGBoost -- trained on ClickMasters historic lending data (28,000 loans, 3-year performance).
Feature importance
- cash flow volatility (most predictive), D&
- B PAYDEX score, director personal credit, SIC code risk profile.
HMRC MTD for SME credit
- HMRC Making Tax Digital provides verifiable financial data for SME credit assessment.
- MTD integration (with borrower consent): (1) HMRC API agent authorisation (borrower authorises platform as HMRC API agent -- MTD OAuth 2.0), (2) VAT returns (quarterly VAT returns -- revenue signal -- more reliable than bank statements for VAT-registered businesses), (3) Corporation Tax (CT600 submitted -- profit and loss data -- annual CT liability), (4) PAYE (HMRC PAYE -- employee headcount -- business scale signal).
HMRC MTD data quality
HMRC data is more reliable than bank statements for credit (HMRC data is verified at source, bank statements can be altered).
ClickMasters
HMRC MTD integration reduces fraud risk by 42% vs bank-statement-only credit.
Loan Management and FCA CONC
FCA CONC loan management for SMEs (loans below GBP25,000 are consumer credit): (1) pre-contract information (SECCI -- Standard European Consumer Credit Information -- required before loan agreement), (2) cooling-off period (CCA 1974 s.67 -- 14-day right to withdraw from consumer credit agreement), (3) monthly statement (FCA CONC 6.7 -- clear monthly statement of outstanding balance, repayments made, charges), (4) arrears management (FCA CONC -- early engagement with borrowers in difficulty -- forbearance first, recovery second), (5) default notice (CCA 1974 s.87 -- default notice before enforcement action).
GoCardless BACS
monthly loan repayments via BACS Direct Debit -- lowest cost, highest reliability for SME loan servicing.
The Results
FCA CONC confirmed.
Platform live at 22 weeks, GBP112,000. 2,800 SME borrowers.
GBP84M loan book.
Digital origination: 18 minutes average.
Companies House pre-fill: 84.2%.
HMRC MTD integration: 68.4% of borrowers (34% fraud risk reduction vs bank-statement-only).
ML credit model: 94.2% first-year repayment rate (vs 88.4% pre-ML).
AML: 100% screened.
ISO 27001 maintained.
Digital origination 18 minutes.
Companies House 84.2% pre-fill.
HMRC MTD 68.4% adoption.
Credit model 94.2% repayment rate.
AML 100%.
ISO 27001.
The HMRC MTD integration -- verifiable VAT and Corporation Tax data alongside Open Banking -- was the fraud detection feature that changed our risk model.
Fraudsters can falsify bank statements.
They cannot falsify HMRC VAT returns.
The 34% fraud risk reduction is real money.
For a GBP84M loan book, 34% less fraud translates directly to improved net interest margin. -- CEO, UK Commercial Lending Platform
Project Details
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