For the CRO and General Counsel
Consumer Duty made "reasonable steps" the test. Most institutions can describe them in a committee paper, but cannot produce the evidence on demand, by construction.
Not because the tools are bad. Because the evidence is disconnected and static.
Decisions live in slides and minutes, not as evidence you can query.
Periodic review, not continuous proof that the controls held.
Agentic decisions arrive faster than committees can meet.
Continuous assurance instead of periodic review. Delegated authority that is traceable to the action it authorised. Decisions that are audit-ready because the evidence is captured as the work runs, not reconstructed after a complaint. Consent and vulnerability handling are absorbed here: Consumer Duty outcomes become accountability evidence, not a separate exercise.
Your control framework stays. We make its evidence continuous and defensible.
The 90-Day Assessment
Take one obligation the CRO must be able to defend. Run it through the five Decision Gates and deliver board-ready evidence that reasonable steps were designed in, not reconstructed.
Fixed price. Fixed duration. Defined deliverable. It closes by surfacing the Knowledge gap: where the evidence trail decays as people leave.
A number and a regime, not adjectives.
75%
reduction in production incidents arising from change at a UK challenger bank, delivered through L1/L2/L3 RACI aligned to value streams and a ServiceNow-to-Jira integration.
Regulatory currency: Consumer Duty (PS22/9); the FCA Mills Review (January 2026) on AI in retail financial services.
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