Every consumer lender on earth runs the same lifecycle: originate, disburse, accrue, bill, collect, resolve. And every market wraps that lifecycle in its own rules — what you must disclose, how payments must be allocated, which notices must be sent before a default, what a customer in difficulty is owed.
Platforms usually respond in one of two bad ways. They hard-code one market's rules and call everything else a customisation project. Or they stay "flexible" and push the entire regulatory burden onto each customer's implementation.
Separate the machinery from the rules
The machinery of lending is market-neutral: an event-sourced ledger, a decision engine, servicing agents, an audit trail. None of it should know what CONC or Regulation Z is.
The rules are not neutral — so they ship as jurisdiction packs: versioned configuration that binds the machinery to one market's obligations.
- The UK pack allocates payments highest-APR-first, generates arrears notices with the right information sheets, and tracks long-term debt against the 18/27/36-month interventions.
- The EU pack implements the Consumer Credit Directive's early-repayment and forbearance articles, with member-state variations as overlays.
- The US pack produces adverse action reasons, handles billing-error disputes within their statutory windows, and applies the payment-allocation order card rules require.
Same ledger. Same agents. Different packs.
Why packs beat projects
Three properties matter:
- Packs are versioned, so a rule change is a diff you can review, test against historical cases and approve — not a change request with a six-month lead time.
- Packs are shared, so the cost of tracking a regulatory change is paid once, not once per lender.
- Packs are inspectable, so your compliance team can read exactly which control implements which obligation, and show the mapping to a regulator.
Entering a new market stops being a replatforming decision. It's a pack, your licences, and your risk appetite — in that order of difficulty, and the pack is the easy one.