OMP Domain Profile: FCA Consumer Duty, SM&CR Accountability, and AI Governance Evidence for UK Retail Financial Services

This document defines a domain profile of the Operating Model Protocol (OMP) for AI systems deployed in UK retail financial services contexts subject to the Financial Conduct Authority (FCA) Consumer Duty (PS22/9, effective July 31, 2023), the Senior Managers and Certification Regime (SM&CR), and the FCA's emerging AI accountability framework as informed by the Mills Review (2026) and the FCA's research on algorithmic decision-making. The profile -- designated DutyMark -- specifies how OMP's deterministic routing invariant, Watchtower enforcement framework, and three-layer cryptographic integrity architecture satisfy the evidence requirements for Consumer Duty outcome testing, SM&CR named accountability, and FCA supervisory examination of AI-assisted retail financial services decisions. The profile covers the four Consumer Duty outcome areas and FCA agent distribution oversight. The OMP core specification is defined in the Operating Model Protocol Internet-Draft (draft-veridom-omp).