Consumer Duty compliance on Salesforce: a workflow problem, not a reporting problem
The FCA didn't ask for better reports. It asked for demonstrably better outcomes — and outcomes live in the day-to-day flow of lending work, not in a quarterly pack.
Why Consumer Duty compliance fails as paperwork
Three years in, many lenders still run Consumer Duty as a retrospective exercise: the work happens in one set of systems, and once a quarter somebody assembles proof that it happened fairly. That model has two failure modes. It's expensive — skilled people spend days reconstructing decisions. And it's fragile — reconstruction is exactly where evidence gaps appear, and a gap discovered during an FCA request is the worst possible time to find it.
The regulator's own language gives the game away: it asked for demonstrably good outcomes, not better reports. Outcomes live in the day-to-day flow of work — which means the only economical place to capture the evidence is inside the workflow itself.
The 2026 supervision phase raises the bar again. The FCA now expects boards to articulate their Consumer Duty narrative, not just table a report — and it increasingly distinguishes firms that actively engage with outcome data from firms that merely report it. For lenders the scrutiny lands on affordability outcomes, arrears trends, repeat borrowing, complaints root-cause and oversight of broker channels — exactly the data a governed workflow produces as a by-product, and a reporting exercise reconstructs at cost.
Encoding Consumer Duty into the lending journey
Mapped to the four outcomes, on the platform most lenders already own:
What an FCA request looks like when the workflow wrote the evidence
The honest caveat
The workflow can evidence the Duty; it cannot absolve it. A product that fails fair value fails it however well the journey documents the sale — and the Duty remains board-owned, with a named champion, whatever the platform does. One more honesty: history is hard. Decisions made before the governed flow existed may not be reconstructable to this standard. That is an argument for starting the clock now, not a reason to wait.
Three questions to ask yourself
How Eminence VSP helps
We build Consumer Duty compliance into Salesforce lending workflows — product rules in the catalogue, comprehension gates in Stage Management, vulnerability routing on one customer record, and a monitoring pack that is a dashboard, not a quarterly project. Start at Solutions or talk to the architect.
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