Start with a product record
Write a product record before opening a legal checklist. Identify the intended borrower, the entity providing credit, any distributor and the markets in which the arrangement is offered. Record the credit amount, repayment structure, interest, fees and contractual term. Describe what happens when payments are late, a purchase is returned or the borrower disputes a transaction. Product names are convenient labels, but they cannot replace this underlying description. A record should be precise enough that a reviewer can distinguish a cash loan from purchase financing or supplier deferred payment.
Separate legal research from control design
Research the applicable framework in each jurisdiction and attach authoritative sources to the product record. Record the law or rule, the provision, its status and the date from which it applies. Then create a separate control map showing who performs the work, at what point in the journey and with what evidence. Keeping these layers separate helps when a rule changes: the legal interpretation can be reviewed without rewriting the entire operating process. A proposed control is an implementation choice until its relationship to the requirement has been reviewed.
Follow the borrower journey
Trace one application from advertisement to application, decision, disclosure, agreement and servicing. At each handoff, ask which system owns the information and which team can explain the result. A disclosure approved by legal may still be delivered too late in a particular digital flow. A servicing team may use terms that differ from the agreement version accepted by the customer. Review both normal journeys and exceptions, including manual decisions, failed deliveries, complaints and arrears.
Build a reviewable evidence chain
Give each control an owner, review frequency and evidence location. Link a decision to its inputs, policy version and any override rather than retaining an isolated outcome. Keep a change log for the product and its supporting communications. This is an editorial operating framework, not a universal set of legal requirements. Its purpose is to organise research and implementation questions so that a qualified reviewer can assess the actual arrangement in its jurisdiction.
Primary sources
European Commission: consumer credit ↗Read the source in its current version. National implementing measures and product-specific applicability may require additional research.