Financial Hardship Policy¶
| Code | CON-008 |
| Domain | Customer & Conduct |
| Owner | Head of Customer Experience |
| Status | Draft |
| Applicability | Platform |
| Jurisdiction | NZ + AU |
| Business domain | BD01 |
| Review date | 2027-03-25 |
Regulations: CCCFA 2003 · NCC Act 2009 (NCCP) · ABA Banking Code · NZ Banking Code¶
Purpose¶
Govern the platform's obligations to identify customers experiencing financial hardship, respond within statutory timeframes, and offer appropriate assistance in accordance with the CCCFA (NZ), NCCP Act (AU), and the NZ and AU Banking Codes of Practice.
Scope¶
All credit products across NZ and AU where the platform is the lender or credit provider. Applies from the point a customer or their representative indicates financial difficulty, or the platform detects hardship indicators through its monitoring systems.
Policy statements¶
The platform SHALL provide a clear, accessible process for customers to apply for hardship assistance. The existence and terms of this process SHALL be disclosed in the product terms, the platform's website, and on any arrears communication.
On receipt of a hardship application, the platform SHALL assess the application and communicate an outcome to the customer within 10 working days (NZ CCCFA s.102) or 21 days (AU NCCP s.72) of receiving all information required to assess the application, whichever applies to the customer's jurisdiction.
During the assessment period, the platform SHALL NOT initiate or continue any collections or enforcement action — including credit default listings, legal proceedings, or external debt referral — against the customer's hardship-affected account.
Where the platform determines that the customer is experiencing genuine financial difficulty and is likely to be able to meet the terms of a variation, the platform SHALL agree to a hardship variation. The variation SHALL be documented and disclosed to the customer in writing before taking effect, including the revised terms and the effect on total interest payable.
The platform SHALL proactively identify hardship indicators through automated monitoring (persistent arrears, sustained high credit utilisation, repeated minimum payments). Where indicators are detected, the platform SHALL initiate proactive outreach before initiating collections activity.
All hardship applications, assessments, decisions, variation agreements, and subsequent performance monitoring SHALL be logged and retained for regulatory examination. Where a hardship application is declined, the reason SHALL be documented and the customer informed of their right to complain.
Fee waivers and interest concessions granted as part of a hardship arrangement SHALL be documented. A hardship arrangement does not waive fees automatically — any fee waiver decision is governed by the fee waiver authority matrix (CON-005).
The platform SHALL review its hardship program annually against industry benchmarks and regulatory guidance. Breach of statutory response timeframes SHALL be reported to the Head of Operations and remediated.
Satisfying modules¶
| Module | Name | Mode | Description |
|---|---|---|---|
| MOD-116 | Mortgage servicing engine | ALERT |
Arrears escalation triggers a hardship flag, routing the account to the financial hardship workflow before collections action. |
| MOD-117 | Overdraft management engine | ALERT |
Customers who are drawn on their overdraft for more than 60 consecutive days are flagged for financial hardship review. |
| MOD-139 | Financial hardship formal variation workflow | GATE |
Hardship applications must be assessed within the statutory timeframe (NZ CCCFA: 10 working days; AU NCCP: 21 days); the system tracks and enforces these deadlines with escalation on breach. |
Part of Customer & Conduct · Governance overview
Compiled 2026-05-22 from source/entities/policies/CON-008.yaml