FCA-compliant mortgage technology, built to Consumer Duty.
A mortgage origination platform for UK brokers. MCOB-compliant from the schema up, with built-in Consumer Duty audit trails.
The challenge
Gable needed to build a mortgage origination platform that could pass FCA scrutiny and meet Consumer Duty obligations — not as a retrofit, but as a design requirement. The platform needed to support multiple broker firms with strict data isolation, generate ESIS/KFI documents on demand, and maintain a complete affordability assessment audit trail.
Our approach
We designed the schema around the FCA's record-keeping requirements before writing the first application route. Affordability assessments are immutable records. ESIS documents are stored with their full input set. Consumer Duty outcome evidence is captured at every touchpoint.
Multi-tenancy was implemented at the database level using row-level security keyed to the broker firm. No broker can access another firm's client data — enforced by the schema, not the application layer.
The AI integration was scoped carefully: Azure AI Search powers document analysis for submitted mortgage applications, with a human review step before any regulated decision is recorded. The AI output is logged alongside the human decision.
The outcome
Platform received FCA provisional approval within the expected timeline. Consumer Duty compliance evidence was produced directly from the system audit trail. The broker onboarding flow reduced from 3 days to 4 hours.
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