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Cavefish
FCA CONSUMER DUTY · REGULATORY SANDBOX

Vulnerable client signals your team can't currently see. EchoDepth makes them visible.

FCA Consumer Duty requires documented evidence that vulnerable customers received appropriate treatment. Standard QA reviews 2–3% of interactions. The vulnerability signal exists in the other 97% — and is never seen.

EchoDepth analyses voice, video and text in real time — detecting distress, anxiety and cognitive overload before harm occurs, and generating the audit trail your compliance team needs.

No wearablesVoice-first for phone callsGDPR compliantFCA Sandbox tested
EchoDepth · Live Vulnerability Detection
KEY PHRASE DETECTED
“I don't know how I'll pay…”
0.22
V · negative
0.91
A · extreme
0.18
D · low
▲ VULNERABILITY FLAG
TIER 2 — FINANCIAL DISTRESS
Route to trained handler · Pause recovery action · Document for Consumer Duty file
Risk Score8.4 / 10
ConfidenceHigh
AU1+4 brow tensionSustained 18s
Action requiredImmediate
All vulnerability determinations remain with qualified staff. EchoDepth provides evidence, not verdicts.
£176M
FCA fines issued in 2024
↑ 230% year on year — Consumer Duty enforcement is accelerating
FCA source →
£479M
Customer redress paid in 2024
Documented failure to identify and act on vulnerability signals
FCA source →
97%
of interactions unreviewed
Standard QA covers 2–3%. The vulnerability signal exists in the rest.

Four-tier framework. Automatic routing.

EchoDepth classifies every interaction against a validated vulnerability tier framework — triggering the appropriate response before harm occurs.

TIER 0
Standard
No flag

No elevated emotional markers. Standard interaction protocol.

TIER 1
Elevated
Monitor

Elevated arousal or low valence. Continue with care. Note in case file.

TIER 2
Financial Distress
Intervene

Significant distress markers. Route to trained handler. Pause recovery action.

TIER 3
Crisis Indicators
Escalate

Extreme distress or crisis-level signals. Immediate escalation. Signpost specialist support.

Designed for where the risk is highest.

01
Compliance

Complaint Escalation

ECA escalations are rarely surprises to the customer. The emotional signals — frustration, distress, a sense of being dismissed — build across every interaction. EchoDepth reads those signals in real time, giving your team the chance to intervene before a complaint becomes a regulatory case.

Sustained elevated arousal — building frustration across a call
Valence drops when specific decisions are communicated
Dominance collapse — customer feeling powerless or dismissed
Temporal escalation pattern — emotional state worsening over time
Consumer Duty — A complaint that escalates after emotional distress signals were present and unaddressed is a documented regulatory failure. EchoDepth closes this gap.
02
Lending

Loan Decision Communications

A loan decline is not just a business decision. For many customers, it arrives at a moment of genuine financial crisis. EchoDepth analyses the communication quality of video affordability interviews, flagging risk signals before a decision is communicated without appropriate care.

Continuous VAD monitoring throughout the application session
Distress flag triggered before decline communication is issued
Vulnerability tier scoring — financial distress and mental health indicators
Automatic routing to trained handlers on threshold breach
Consumer Duty — The manner in which a decline is communicated can determine whether a customer spirals into harm or receives appropriate support. Consumer Duty requires evidenced appropriate treatment.
03
Collections

Debt Recovery Interactions

Vulnerable customers are disproportionately represented in collections portfolios — and disproportionately harmed by inappropriate treatment. EchoDepth provides collections teams with real-time vulnerability signals, flagging the moment they emerge so interactions can be redirected before harm occurs.

Voice-first vulnerability detection during phone calls
Tier classification: financial distress, mental health indicators, situational vulnerability
Automatic redirect to trained vulnerability handlers on flag
Session report with vulnerability evidence for regulatory file
Consumer Duty — FCA enforcement against collections failures is increasing. Documented evidence that vulnerability was identified and acted upon is a regulatory requirement, not a best practice.
04
Fraud

Fraud & Claims Investigation

Fraud investigators deal daily with distinguishing genuine distress from performed distress. EchoDepth adds a physiological layer independent of what the subject says — identifying moments where the emotional profile diverges from what a genuine account would produce.

Baseline establishment from session opening minutes
Topic-linked anomaly detection — which questions triggered which responses
AU24 lip press and AU17 chin raiser — suppression markers
Structured report with timestamped anomalies for the case file
Consumer Duty — This is not lie detection. It is the identification of physiological inconsistency — flagged for qualified human review, not automated determination.

The maths is straightforward.

Reducing escalations by 25% saves nearly half a million pounds annually — before accounting for reduced FCA scrutiny, avoided fines and reputational protection.

Annual volume modelled50,000 vulnerable interactions
Vulnerability detection improvement+15%
Escalation rate reduction−25%
Estimated annual savings£467,000
Proof of Concept cost£50,000
Year one ROI3.1×

Illustrative model based on a UK retail bank with 50,000 vulnerable customer interactions per year. Full methodology available on request.

FCA fine avoidance

£176M in fines issued in 2024. Documented Consumer Duty evidence is your primary defence against enforcement action.

Proactive remediation

Intervening before harm occurs costs a fraction of post-complaint remediation at £200–600 per case.

Reputational protection

Documented vulnerability assessment process demonstrates regulatory maturity to the FCA, boards and investors.

Consumer Duty evidence

Every session generates a timestamped vulnerability assessment record — the audit trail Consumer Duty requires.

“EchoDepth does not detect lies. It measures the involuntary physiological markers that accompany stress, cognitive load and emotional state change. What organisations do with those signals is a matter of process, policy and human judgement.”

CAVEFISH · ETHICS FRAMEWORK · THIS DISTINCTION IS NON-NEGOTIABLE IN EVERY DEPLOYMENT

Common questions

How does EchoDepth support FCA Consumer Duty compliance?

EchoDepth detects emotional distress, anxiety and cognitive overload signals in customer interactions — generating a Vulnerability Signal Score and timestamped audit record for every session. This creates documented proof that vulnerability was assessed for every interaction, directly satisfying Consumer Duty evidencing requirements.

Does the customer need to self-declare vulnerability?

No. EchoDepth detects vulnerability signals from vocal patterns, speech pace, hesitation patterns and linguistic markers — without relying on customers to identify or disclose their own situation. This is particularly important for customers experiencing mental health challenges, bereavement or acute financial distress who may not recognise or wish to declare their vulnerability.

What modalities does EchoDepth analyse for vulnerability detection?

EchoDepth is voice-first for phone-based interactions — where most collections and complaint calls happen. It also analyses video (facial Action Units, expressions), text (transcripts, written communications) and still images. The modality is matched to the interaction type.

What is the typical ROI?

Based on a 50,000 vulnerable case annual volume: EchoDepth improves vulnerability detection rates by approximately 15% and reduces escalation rates by approximately 25% — generating estimated annual savings of £467,000 against a PoC cost of £50,000. ROI in year one: approximately 3.1×. Full methodology available on request.

Is EchoDepth GDPR compliant for financial services use?

Yes. Cavefish operates under UK GDPR and ICO frameworks (ICO registration ZB915623). All deployments include explicit informed consent architecture and a signed Data Processing Agreement. EchoDepth has been used within the FCA Regulatory Sandbox.

How does EchoDepth avoid becoming a substitute for human judgement?

EchoDepth generates evidence and flags — it does not make decisions. All vulnerability determinations, interaction redirects and customer outcomes remain with qualified staff. The platform provides the physiological evidence layer that supports human decision-making under Consumer Duty.

See EchoDepth on a real customer interaction.

Submit a recording or transcript from a customer interaction. We return a full EchoDepth vulnerability analysis within 5 working days — free, no commitment.

Request Free Analysis →Book a Demo

ICO registered ZB915623 · FCA Regulatory Sandbox · UK GDPR compliant · hello@cavefish.co.uk