Context

The regulatory plan existed. The product audit did not.

Credit Karma needed to show its products were ready for the UK’s new Consumer Duty rules. The Board had approved a wider programme and Compliance had completed a gap analysis, but nothing assessed the end-to-end member experience across products and teams.

The requirement

Documented evidence of readiness, including avoidance of foreseeable harm, before the July 2023 deadline.

The reality

Journeys had been built piecemeal. No single team held a complete view of a service or the risks running through it.

I designed the product audit and turned its findings into owned action.

Audit scope

Six weeks, focused where the risk was greatest

A full audit wasn’t realistic, so I chose three areas with distinct member and business risks. That gave the audit real breadth without reducing it to a superficial review of every screen.

Member support

Account recovery, thin credit files and disputes drove contacts and complaints.

Car finance

An external provider created an unclear boundary during a consequential journey.

Credit cards

The largest revenue stream, with lessons for other marketplaces.

Approach

I audited the service, not just the screens

An interface review would find usability problems, but not the risks created between teams, support processes, technical systems and partners.

Workshops

Disagreement became evidence

I ran three workshops with around 50 attendances across eight functions. Groups mapped the same journeys independently. Where their maps diverged, the disagreement exposed product, process and ownership risks no single team could see.

Teams then repeated the journeys with vulnerability cards covering dyslexia, temporary impairment, English as an additional language and financial vulnerability. We assessed key content against a reading age of 11 or below.

“I’ve worked here for three years, and this is the first time I’ve looked at the product from a member’s point of view.”
Head of Legal and Compliance

Findings

From small problems to a prioritised backlog

Barriers

Small problems were creating larger barriers

Individually minor issues combined into journeys that were hard to recover from, and unclear about where Credit Karma’s responsibility ended.

  • Account recovery. Password-reset help led to the generic Help Centre.
  • Contacting support. Members completed a form, then learned it hadn’t been sent.
  • Partner journeys. Members moved to another company’s application without a clear transition.
Audit board showing credit card marketplace and dashboard screens surrounded by colour-coded sticky notes recording risks, questions and content observations.
Credit card journeys under audit. Each note is a risk, an assumption or content that wouldn’t hold up for a member in difficulty.
Test data

The members at greatest risk were missing from our test data

QA accounts showed every available card, and employee accounts skewed financially secure. Teams couldn’t reproduce thin files, high debt, defaults or repeated declines, the very circumstances the regulation cares about.

I recommended representative profiles so design, engineering and compliance could test realistic risk states.

Diagram: QA and employee test accounts cover only the strongest member circumstances, leaving thin files, high debt, defaults and repeated declines untested. What our accounts could show QA accounts Dummy data Every marketplace card shown Employee accounts Real data, but skewed Financially secure profiles What they could not Members at risk Thin files, high debt, defaults Repeated declines Recommendation: representative test profiles So teams can evaluate risk states before release, not after complaint

What our accounts could show

QA accountsDummy dataEvery marketplace card shown
Employee accountsReal data, but skewedFinancially secure profiles

What they could not

Members at riskThin files, high debt, defaultsRepeated declines
Recommendation: representative test profilesSo teams can evaluate risk states before release, not after complaint
The gap in our test data. Teams were approving journeys they could not experience as a member in difficulty would.
Hand-off

A hidden partner hand-off, made explicit without an extra click

Choosing ‘buy a car’ moved members into a CarFinance247 application. Similar branding hid the hand-off at exactly the point browsing became applying.

Business Development worried an extra step would hurt conversion; Legal and Compliance needed the provider and credit implications to be clear. Both were reasonable, which made it a design problem rather than a policy one.

Service-level audit board for the car finance journey, showing member-facing screens across lanes with risk notes attached.
The car finance journey across lanes. The hand-off sits in the middle, unmarked.
Prioritisation

The workshops were not the output

I tied each finding to a potential harm, then rated it with Design, Product, Engineering, Legal and Compliance together. Running it as a joint estimate separated immediate regulatory risks from longer-term improvements.

This gave the Board product evidence for its readiness assessment, documented in April 2023.

Diagram: each finding moved from evidence, to potential harm, to a risk rating, to an effort estimate, to a named owner. Evidence Potential harm Risk Effort Owner Every finding ended with a named team and a next action, not a report.
  1. Evidence
  2. Potential harm
  3. Risk
  4. Effort
  5. Owner

Every finding ended with a named team and a next action, not a report.

The prioritisation chain, from evidence to a named owner.

Impact

Support demand fell, and member outcomes shaped product work

66%

fewer account-recovery tickets. Account recovery moved from the number-one support issue in 2023 to number four in 2024.

~40k

fewer support contacts. At the organisation’s internal estimate of £100 per contact, this represented around £4 million in equivalent support costs.

50%

fewer queries passed to TransUnion. Fewer member queries were forwarded from Member Support to the credit reporting agency.

Member outcomes became part of product scoping

Product briefs added ‘member outcomes’ and ‘foreseeable harm’, while Compliance champions brought that perspective into teams.

The approach reached beyond the UK

US partners adopted similar workshops for compliance and customer-satisfaction work.

Figures reported across the available comparison periods reflect the wider Consumer Duty programme and the combined work of several teams. The support-cost equivalent is an estimate, rather than a confirmed cash saving.

Reflection

What I learned

Connect the evidence to the decision

Workshops produce observations. Making each one carry a potential harm, a risk rating, an effort estimate and a named owner meant a regulatory obligation reached teams as a backlog they had helped build, rather than a report they had to interpret.

Thanks to

Fadi Dagher Head of Design, Yasser Masood Head of Compliance and everyone across Product, Engineering, Support, Business Development, Legal, Compliance, Risk and Security who took part in the three workshops.