OCTAGON Business Process Management. Challenges with the NCAA and Company Credit Policy
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OCTAGON Credit Processes & Loans Administration. Business Process Management. Challenges with the NCAA and Company Credit Policy
Who is Octagon? “Octagon is a leading solutions provider for Credit application processing and Loans management in South Africa.” Specialising in the Credit & Loans environment since 1998 Own products built and maintained by Octagon in SA Systems and integration is deployed in Credit Bureaus, Telkom, Major Retailers, Financial Institutions, Attorneys, Estate Agencies & Credit Grantors Products for Credit Application Processing and Decisioning, Account Management & Collections. Clients: Furniture & Clothing Retailers, Asset Based Finance, Vehicle Finance, Microlenders, Attorneys, Mortgage Originators, Estate Agencies and Small Business. Fully integrated Loans Management System product with Format 700V2 reporting. Copyright © Octagon -2019
Credit Application Processing Customer acquisition (Sales channels Web, SMS) The Company Credit Vision Know your Customer KYC Cradle to the Grave Credit Strategy Credit Decisions Reports & Records Copyright © Octagon -2019
Customer acquisition Traditional channel own sales force, formal marketing, internet marketing, social media. Utilizing existing customers who are paid up and pre vetted Finding qualified leads Getting pre vetted approved client lists. Getting leads via web, short message code SMS channel or using USSD. Copyright © Octagon -2019
OCTAGON THE CREDIT PROCESS VISION Information Sources Credit Bureaus SACRRA Software Products WEB WWW or V P N Enabling Transactions DATA SWITCH (SPOC) Value Ads. Loyalty Insurance etc. Usage Apps & Billing Processing Back office Score engines. Financial Providers Decision process Loan administration Treasury, Internal Data CRM Copyright © Octagon -2019
DON’T Judge too quickly Copyright © Octagon -2019
NCAA To amend the National Credit Act, 2005, so as to amend certain definitions; to provide for the alteration of the governance structure of the National Credit Regulator; to empower the Chief Executive Officer to delegate certain functions to other officials of the National Credit Regulator; to provide for the registration of payment distribution agents; to tighten measures relating to debt counsellors and the conduct of their practices as debt counsellors; to allow registrants to voluntarily cancel their registration; to empower the Minister to issue a notice for the removal of adverse consumer credit information; to provide for automatic removal of adverse consumer credit information; to empower the National Consumer Tribunal to declare a credit agreement reckless; to provide for the registration and accreditation of alternative dispute resolution agents; and to provide for matters connected therewith. Copyright © Octagon - 2019
Automatic removal of adverse consumer credit information „„71A. (1)The credit provider must submit to all registered credit bureaux within seven days after settlement by a consumer of any obligation under any credit agreement, information regarding such settlement where an obligation under such credit agreement was the subject of— (a) an adverse classification of consumer behaviour; (b) an adverse classification enforcement action against a consumer; (c) an adverse listing recorded in the payment profile of the consumer; or (d) a judgement debt. The credit bureau must remove any adverse listing contemplated in subsection (1) within seven days after receipt of such information from the credit provider. If the credit provider fails to submit information regarding a settlement as contemplated in subsection (1), a consumer may lodge a complaint against such credit provider with the National Credit Regulator. For the purposes of this section— (a) „adverse classification of consumer behaviour‟ means classification relating to consumer behaviour and includes a classification such as „„delinquent‟‟, „„default‟‟, „„slow paying‟‟, „„absconded‟‟, or „„not contactable‟‟; and (b) „adverse classification of enforcement action‟ means classification relating to enforcement action taken by the credit provider, including a classification such as „„handed over for collection or recovery‟‟, „„legal action‟‟, or „„write-off‟‟.‟‟. Copyright © Octagon - 2019
Application of prescription on debt No person may sell a debt under a credit agreement to which this Act applies and that has been extinguished by prescription under the Prescription Act, 1969 (Act No. 68 of 1969). No person may continue the collection of, or re-activate a debt under a credit agreement to which this Act applies— (i) which debt has been extinguished by prescription under the Prescription Act, 1969 (Act No. 68 of 1969); and (ii) where the consumer raises the defense of prescription, or would reasonably have raised the defense of prescription had the consumer been aware of such a defense, in response to a demand, whether as part of legal proceedings or otherwise. Copyright © Octagon - 2019
CRITERIA TO CONDUCT AFFORDABILITY ASSESSMENT APPLICATION These Regulations apply to: (a) current, prospective and joint consumers; (b) all credit providers; and (c) all credit agreements to which this Act applies, subject to Regulation 2. These Regulations do not apply to a credit agreement in respect of which the consumer is a juristic person and do not apply to: (a) a developmental credit agreement; (b) a school loan or a student loan; (c) a public interest credit agreement; (d) a pawn transaction; (e) an incidental credit agreement; (f) an emergency loan; (g) a temporary increase in the credit limit under a credit facility; (h) a unilateral credit limit increase in terms of sections 119(1)(c);119(4); and 119(5) of the Act under a credit facility; (i) a pre-existing credit agreement in terms of Schedule 3 Item 4(2) of the Act; (j) any change to a credit agreement and/or any deferral or waiver of an amount under an existing credit agreement in accordance with section 95 of the Act; And (k) mortgage credit agreements that qualify for the Finance Linked Subsidy Programs developed by the Department of Human Settlements and credit advanced for housing that falls within the threshold set from time to time. Copyright © Octagon - 2019
A credit provider must make a calculation of the consumer's existing financial means, prospects and obligations as envisaged in sections 78(3) and 81(2)(a)(iii) of the Act. The credit provider must utilise the minimum expense norms table below, broken down by monthly gross income when calculating the existing financial obligations of consumers. The methodology in the table requires for: (a) credit providers to ascertain gross income; (b) statutory deductions and minimum living expenses to be deducted to arrive at a net income, which must be allocated for payment of debt instalments; and (c) when existing debt obligations are taken into account, the credit provider must calculate discretionary income to enable the consumer to satisfy any new debt. Table l: Minimum Expense Norms Minimum Maximum Minimum monthly Fixed Factor Monthly Fixed Factor = % of Income Above Band minimum R0.00 to R800.00 R0.00 100% R800.01 to R6,250.00 R800.00 6.75% R6,250.01 to R25,000.00 R1,167.88 9.00% R25.000.01 to R50,000.00 R2,855.38 8.20% R50,000.01 Unlimited R4,905.38 6.75% The credit provider may however on an exceptional basis, where justified, accept the consumer's declared minimum expenses which are lower than those set out in table 1 provided the questionnaire set out in the Schedule, as issued from time to time, is completed by the consumer or joint consumers. When conducting the affordability assessment, the credit provider must: (a) calculate the consumer's discretionary income; (b) take into account all monthly debt repayment obligations in terms of credit agreements as reflected on the consumer's credit profile held by a registered credit bureau; and take into account maintenance obligations and other necessary expenses . Copyright © Octagon - 2019
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Existing financial means and prospects A credit provider must take practicable steps to assess the consumer or joint consumer's discretionary income to determine whether the consumer has the financial means and prospects to pay the proposed credit instalments. A credit provider must take practicable steps to validate gross income, in relation to: (a) consumers that receive a salary from an employer: (i) latest three(3) payslips; or (ii) latest bank statements showing latest three(3) salary deposits; (b) consumers that do not receive a salary as contemplated in (a) above by requiring: (i)(ii) latest three(3) documented proof of income; or latest three(3) months bank statements; (c) consumers that are self-employed, informally employed or employed in a way through which they do not receive a payslip or proof of income as contemplated in (a) or (b) above by requiring: (1) latest three (3) months bank statements; or (ii) latest financial statements. Where the consumer's monthly gross income shows material variance, the average gross income over the period of not less than three (3)pay periods preceding the credit application must be utilised. The consumer must accurately disclose to the credit provider all financial obligations to enable the credit provider to conduct the affordability assessment. The consumer must provide authentic documentation to the credit provider to enable the credit provider to conduct the affordability assessment. Copyright © Octagon - 2019
CREDIT STRATEGY Single Customer View Information Sources Credit Information • Experian Online Financing • Transunion Property Info • XDS Online Insurance • Compuscan Bank Acc • NLR / CPA Verification •Profiler •Deeds Offices •Frontier • SAPTG •Dossier • Refcheck •Credit Office WWW • Criminal records Clients • SAFPS • ID Verification Value Adding SWITCH Services (SPOC) • Pre Approvals • Term Life Integrations Monthly • Credit Life, Loan Management Billing • 3rd Party service providers Collections Applications Financial Processed Processes CREDIT REPORTING • Account Validations Total Applications, Referrals, Approvals, Declines • Check own Data • Disbursement Management Reporting • Global Exposure Total Book, Loan Values, Monthly House Keeping Financials. • Collections, D/O, ADOS 2017 Copyright © Octagon -2019
THE STATE OF CREDIT RISK ANALYTICS IN FINANCIAL SERVICES SURVEY RESULTS Who we spoke to In July 2015, FC Business Intelligence conducted a survey of North American Financial Services credit risk professionals There were over 125 respondents in total This is the amount of time they currently spend on analytics: NOT MUCH A SMALL A MODERATE AT ALL AMOUNT AMOUNT 15% 8% 50% THE MAJORITY ALL OF OF MY TIME MY TIME 25% 2%
Key Findings from the Survey 87% of financial services industry agreed that “Analytics is the biggest game-changer for the credit risk industry in 2014 - 35% 2015” of credit risk industry professionals said that they have seen good to transformative results from the use of analytics $ 100 37% 100 100 $ 100 of credit risk professionals are starting to see small rewards from analytics incentives 72% of credit risk professionals believe that there will be constant changes to their analytics platform moving forward
Q - Since 2010, how much has analytics changed credit risk in your organization? GO Not much at all A small amount Stayed the same Changed slightly Changed dramatically 6% 5% 2% 30% 57% Q - Does your current data analytics strategy allow you to more effectively manage credit risk?
Q - Which of these roles are spearheading analytics in the organization? Chief Chief Executive Officer 12% Chief Compliance Officer 10% Credit Officer 15% Chief Chief Financial Officer 10% Risk Officer 35% 9% 2% 4% 3% Chief Chief Data/Analytics Operating Officer Chief Chief Officer Marketing Information/ Officer Technology Officer Q - What are the top 3 challenges in deploying credit risk analytics within your organization? Accessing th th st 4 expertise and 5 Responding to regulatory/ 1 2 nd 3 rd identifying the right people for the job shareholder expectations Enterprise- Modelling Restructuring data and th th Stress wide analytics integration employing predictive siloed data and legacy systems 6 Applying new software and system 7 testing and responding analytics to risk solutions scenarios th Sourcing th 8 external structured/ 9 Detecting fraud and privacy unstructured concerns data
Q - What are the top 3 drivers for employing new credit risk analytics within your organization? Minimized risk related losses 72% Regulatory changes 65% Maintain a competitive edge 43% Increased transactional speed and efficiency 40% Access to new analytics competencies 28% Customer expectations 20% Better customer relations 17% Company shareholder requirements 15%
(BPM) Business Process Management Cradle to Grave Credit Application Application Quotation Capture Credit Vetting Credit Min Policy Affordability Bureau Fraud Check Rules Check Enquiry Authorization Contract Account Approval Disbursement Generation Creation ACCOUNT MANAGEMENT & MONITORING COLLECTIONS, DEBT REPAIR Copyright © Octagon -2019
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Why use Octagon Registered reseller Credit bureau NCRCB43 +-1000 companies use our software products Specialist’s in all forms of finance, Micro to Home Loan. Octagon Gateway switches +-12 million transactions per annum Process credit applications +- R500 million per month Approximately R8 Billion under management Automatic approvals within 30 seconds Consistently applies business & credit strategy uniformly Full MIS reporting and Performance statistics. Copyright © Octagon Business Solutions -2019
Records Credit provider must maintain the following information – for 3 years after the termination of the agreement or decline of application – Consumers full name and surname – ID or passport and date of birth – Date granted, amount, instalment amount, number of instalments – Defaults – Date terminated and reason Copyright © Octagon -2019
The Road Ahead Copyright © Octagon Group -1998
Questions “The most fertile source of insight is hindsight.” Morris Kline (Mathematics: The Loss of Certainty, 1980 ) “May you have the hindsight to know where you've been, The foresight to know where you are going, And the insight to know when you have gone too far.” Irish Blessing Thank you Copyright © Octagon -2019
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