A UK lender's loan-decisioning loop, rebuilt with dual-geo delivery.
London-based UK lender, ~£80M loan book. London-led FCA strategy. Manila-built decisioning agents. The case study no pure-UK and no pure-PH AI firm could deliver.
Photo: Unsplash. Client name anonymised per FCA / NDA.
36 hours to decide a £20k SME loan. Three competitors did it in 90 seconds.
The client is a UK-based specialist lender with an ~£80M loan book, focused on SME working-capital facilities. Underwriting was 60% manual: spreadsheet-based affordability, two underwriter reviews, manual risk scoring, manual document checks. Median application-to-decision latency was 36 hours. Conversion from approved-to-funded had been declining for six consecutive quarters because applicants who waited 36 hours had already accepted offers from challenger competitors who decided in 90 seconds.
The structural challenge: the client could not just "automate decisioning". Every model had to be FCA-auditable. Adverse decisions had to come with explainable reasoning. The data sources included Companies House feeds, Open Banking transaction histories, and proprietary repayment data — each with different residency and consent constraints.
A pure-UK firm would have been too expensive. A pure-PH firm would have failed the FCA review.
A pure-UK consultancy quoted £1.4M for the build alone, with no commitment on go-live date. A pure-PH offshore shop quoted £210k, but the lender's Compliance Director declined — the offshore team had no FCA-adjacent prior work and could not articulate what an SM&CR-aligned model card looked like.
Xamun's structure resolved both. Two London-based partners (one from financial services background) held FCA-side strategy, model governance and Compliance Director-facing artefacts. The Manila Software Factory held the engineering build. The dual-geo loop closed weekly between London and Manila — and the client's Compliance Director sat in on UK-side governance reviews every other Friday.
Five 21-day cycles. London ↔ Manila weekly.
Diagnose + FCA framing
XI mapped the existing decisioning workflow against FCA conduct-risk principles. Model governance framework drafted. Explainability requirements documented.
Data ingestion
Open Banking, Companies House and internal repayment data integrated. Data residency stayed UK-side (Azure UK South); engineering ran against synthetic mirrors in PH.
Affordability + risk model
Gradient-boosted affordability model + LLM-driven document parser. Every decision produced a structured reasoning trace and a model-card-aware audit log.
Underwriter copilot
For the ~22% of applications outside automated tolerance, a human-in-the-loop dashboard surfaced the AI's reasoning and let the underwriter override + record why.
Integration + shadow run
Decisioning agent ran in shadow mode for 3 weeks alongside the existing manual workflow. London team compared decisions; gaps reviewed weekly.
FCA submission + go-live
Model documentation, governance pack and go-live signoff. PlayStudio dashboards live for Compliance Director on day one.
What actually moved.
Median application-to-decision. P95 stayed under 22 minutes including manual reviews.
Conversion uplift attributable to decision speed. £14.4M incremental funded volume in Q1 post-launch.
90-day default rate held within the lender's pre-set FCA tolerance band. No risk drift over the first 6 months.
Every decision produces a structured reasoning trace. Compliance Director can audit any record end-to-end.
£196k total. Roughly 1/7 of the pure-UK quote.
Five 21-day cycles, a London-led XI Discovery, and a 6-week embed phase. Total contracted value: ~£196k. The pure-UK consultancy quote for the equivalent build was £1.4M with no go-live commitment. The pure-PH offshore quote was £210k but failed Compliance Director review. Xamun's £196k delivered the build AND the FCA-aware artefacts the Compliance Director needed to defend it.
Payback against the £14.4M incremental Q1 funded volume: weeks, not quarters.
UK regulated business. Offshore-shy. Talk to us anyway.
We can show you the FCA-aware governance pack from this engagement, the model card framework, and the Compliance Director walkthrough — under NDA — on a half-day Discovery.