Merchant training only counts if merchants finish it
A curriculum with a 30% completion rate is a compliance artifact, not a control.
Compliance that costs a contractor an afternoon will be worked around by lunchtime.
The failure mode of merchant-facing compliance is not refusal. It is adaptation. A contractor who finds the documentation flow slower than the paperwork it replaced will find the shortest path that still gets them paid — batching photos at the end of the week, having an office manager complete the borrower's step, collecting signatures on a device that is not the borrower's.
None of those are malicious. Each is a rational response to friction. All of them destroy the evidentiary value of the record while leaving the record apparently complete, which is the worst of both outcomes.
Time the compliant path against the path it replaced. If it is slower, the control is theatre, however well-designed. Documentation done properly should be faster than documentation done badly, because doing it badly generates disputes and disputes cost weeks.
If the compliant path is slower than the path it replaced, you have not built a control. You have built an obstacle, and obstacles get walked around.
Because the lender is the party holding the risk when the record turns out to be hollow. A merchant who routes around a control has not transferred the consequence to themselves. Merchant experience is not a courtesy in this market — it is the mechanism by which your evidence stays real.
Watch a contractor complete a draw for the first time without help. Wherever they hesitate is where the evidence will eventually degrade.
Pick a closed project. We will show you the document you would hand a regulator. If it does not answer the question, nothing else matters.