Credit compliance governance, controls and enforcement
How lenders structure credit compliance programmes, policies, controls, monitoring, investigations, enforcement readiness and evidence.
Credit Compliance Governance Explained
Credit compliance governance is the arrangement of accountability, oversight, policies, controls and reporting through which a credit provider identifies and manages obligations.
Roles and Responsibilities in a Credit Compliance Team
A credit compliance team works only when the organisation can identify who owns each obligation, who performs the control, who reviews the outcome and who can approve remediation.
How to Build a Credit Compliance Policy Framework
A credit compliance policy framework translates applicable laws into clear decisions about products, customers, processes and evidence.
Credit Compliance Risk Assessments
A credit compliance risk assessment identifies where the lender might breach applicable obligations or cause legally relevant consumer harm.
Regulatory Change Management for Credit Providers
Regulatory change management is the process of identifying an incoming rule, deciding whether it applies to a credit provider, updating the relevant controls and retaining evidence of implementation.
Compliance Controls Across the Lending Lifecycle
A lending lifecycle contains several decisions, each with different legal and operational risks: advertising, application, creditworthiness assessment, offer, contract, servicing, financial difficulty and closure.
Credit Compliance Monitoring
Credit compliance monitoring is the recurring review of whether day-to-day lending activity follows applicable legal requirements and internal controls.
Credit Compliance Testing
Credit compliance testing determines whether particular controls work on actual transactions, not merely whether a procedure exists.
Credit File Reviews and Sampling
A credit file review inspects a particular application or account record to see whether relevant lending obligations and controls were met.
Internal Credit Compliance Audits
Internal audit provides an independent assessment of governance, risk management and controls, whereas compliance monitoring and testing may be conducted as an ongoing second-line activity.
Compliance Evidence and Recordkeeping
Credit compliance evidence should connect a legal obligation to a business process and a verifiable result.
Managing Credit Compliance Breaches
A credit compliance breach is an actual or suspected failure to meet an applicable requirement, not every operational error.
Consumer Credit Complaints Management
A consumer credit complaint can concern an advertised rate, an unexplained rejection, an inaccessible disclosure, incorrect account data, collection conduct or difficulties exercising a contractual right.
Root-Cause Analysis for Credit Compliance Failures
Root-cause analysis begins with a precise description of what went wrong, when it started and which credit products, customers or jurisdictions were affected.
Regulatory Investigations of Credit Providers
A credit provider may receive enquiries from consumer-credit supervisors, data protection authorities, conduct regulators or authorities responsible for banking prudential oversight.
Credit Compliance Enforcement and Penalties
Enforcement consequences depend on the rule infringed, the national law, the regulated person and the competent authority.
Preparing for a Consumer Credit Regulatory Review
A consumer-credit regulatory review may examine one product, an authorised institution, an entire lending business or a specific conduct problem.
Building a Credit Compliance Evidence Library
A credit compliance evidence library should make it possible to demonstrate what customers were told, what decisions were made and which controls operated at the relevant time.
Credit Compliance Management Systems
A credit compliance management system combines responsibilities, documented procedures, risk assessment, monitoring, testing, issue management and reporting.
How to Build and Operate a Credit Compliance Program
A credit compliance programme maps each applicable consumer-credit obligation to an accountable owner, documented policy, operational control, evidence and review process across the lending lifecycle.
Put the topic in context.
Choose a jurisdiction before applying a rule. Use the sources attached to each guide and record unresolved product questions.