Consumer Duty, Business Architecture and the Evidence Tax
Consumer Duty isn’t testing products, it’s testing organisational design. Why the hardest part of proving good customer outcomes is finding the evidence.
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Longer-form thinking on banking transformation, organisational design, credit risk, embedded finance and regulatory change.
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Agentic lending doesn’t break underwriting. It breaks the audit trail.
Automated lending is decades old. Agentic lending is different. When a system gathers its own evidence and acts in milliseconds, the question is whether anyone can reconstruct the decision.
Read the full piece →Credit underwriting is a craft. A pure science can’t lend.
Banks are handing lending decisions to machines and calling it progress. But lending was never a problem with a right answer waiting to be calculated. This is the long version of why.
Read the full piece →Embedded FinTech: why value chains, not banks, are the new battleground
Embedded finance is not about blurring boundaries between banks and platforms. It is about where the margin goes, and who is built to capture it.
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