Regulatory Compliance Policies and Procedures
A sound compliance program is one of the General Conduct Obligations for an Australian Credit Licence holder, under the NCCP Act.
All businesses, regardless of their industry, have obligations that they must meet. These obligations arise from a variety of sources including:
- laws and regulations
- internal policies and procedures
- contractual arrangements
- risk treatment (continuous improvement) initiatives.
As well as being a negative expression of who we are as a business, failure to meet our compliance obligations can have a range of consequences from customer complaints and loss of customers to fines and legal sanctions.
Complying with our obligations means we are doing the right thing and most importantly allows us to focus on our core business without distraction. Compliance leads to increased productivity, increased profitability and increased business value.
An effective compliance programme can help all staff understand their obligations and reduce the risk of breaching their obligations.
The Credit Licensee needs to demonstrate it:
- Has all the appropriate policies;
- Has a documented schedule (we recommend quarterly) to test itself against the policies;
- Documents the testing results; and
- Takes any necessary actions arising out of the results.
Of course, the above also applies to the obligations around the responsible lending process (file audits). However, we have observed that the industry seems to have forgotten about the other obligations, which are just as important. Failure to meet all your compliance obligations can have a range of consequences from customer complaints and loss of customers to fines and legal sanctions.
QED will develop a Compliance Program for you that will be be aligned with AS 3806-2006 and best practice in the industry.
To ensure your NCCP compliance you need to test yourself against all your policies regularly, document the results and take action to fix any areas of non-compliance.