UK lender reduces complaint escalation
with real-time vulnerability detection.

The challenge

A mid-tier UK lender processing approximately 40,000 personal loan applications per year identified a recurring pattern: a proportion of declined applicants were filing complaints that escalated to the Financial Ombudsman Service (FOS). Internal review showed that in many of these cases, the applicant had displayed signs of emotional distress during the affordability interview — but these signals had not been identified or documented at the time of the decision.

Under FCA Consumer Duty, the lender needed to demonstrate that vulnerability was assessed before consequential decisions were communicated. Their existing process — post-call quality review of a random 5% sample — was not sufficient. The gap was not process. It was detection.

The deployment

EchoDepth was deployed as a 12-week proof of concept across the lender's video affordability interview workflow. The integration:

• EchoDepth analysed video and voice streams during live affordability interviews via WebSocket
• VAD scores were computed per frame with baseline calibration from the session opening
• Alert thresholds were configured for the lending context: arousal > 0.80, valence < 0.25, dominance < 0.30
• When thresholds were breached, staff received a real-time flag recommending pause, re-routing or additional support
• Full session reports were generated for every interview — creating the Consumer Duty audit trail

What was found

The most significant finding was that approximately 60% of vulnerability flags identified by EchoDepth had not been detected by the interviewing staff. These were not cases of negligence — they were cases where the customer presented as calm and cooperative while physiological markers indicated significant distress. This is precisely the gap that text and keyword-based systems cannot close.

The outcome

Following the PoC, the lender moved to a full deployment across their affordability interview workflow. Key outcomes:

• Consumer Duty documentation — every interview now generates a timestamped audit trail documenting that vulnerability was assessed before the lending decision
• Staff confidence — interviewers reported that the real-time flag gave them "permission" to pause and redirect conversations they instinctively felt were difficult but had no data to support
• Compliance team efficiency — quality review shifted from random sampling to targeted review of flagged sessions, reducing review volume while increasing coverage of high-risk interactions
• Reduced escalation trajectory — early indicators showed a measurable reduction in complaints reaching the FOS from the affordability workflow