Commission consent

A Court of Appeal ruling changed the legal requirements around how broker commission had to be disclosed and consented to. Close Brothers' existing onboarding flow didn't meet the new FCA requirements, exposing the business to significant regulatory risk.

The constraints were significant: seven weeks from brief to launch, FCA-compliant consent language and disclosure rules, had to work across all broker relationships without disrupting existing journeys, mobile-first with 78% of traffic coming from mobile devices, and fully accessible for customers with varying levels of digital confidence.

Discovery was led by my Head of Design, and I worked closely alongside him to map the existing onboarding ecosystem and understand where a standalone service could sit without breaking broker relationships. Together we supported the service blueprint that aligned over 50 people across product, engineering, legal, compliance, and customer insight.

I collaborated with a Senior Designer on ideation and the end-to-end journey, from low fidelity through to production-ready, keeping FCA consent requirements central to every decision. I co-ran 22 customer interviews with the insight team and supported over 45 broker walkthroughs throughout delivery, feeding findings directly back into the design. Post-launch, behavioural data identified a login issue. We owned the fix that reduced errors by 85%.