Responsible Lending Policy¶


Code	`CRE-002`
Domain	Credit Risk
Owner	Head of Credit Risk
Status	Draft
Applicability	Platform
Jurisdiction	NZ + AU
Business domain	BD05
Review date	2027-03-25

Regulations: CCCFA 2003 · NCC Act 2009 (NCCP) · ASIC RG 209 ¶

Purpose¶

Govern the platform's responsible lending obligations under the NZ Credit Contracts and Consumer Finance Act 2003 (CCCFA) and the AU National Consumer Credit Protection Act 2009 (NCCP Act). Ensures that credit is only extended to customers for whom it is suitable and where repayment will not cause substantial hardship.

Scope¶

All consumer credit products extended to natural persons and small businesses in NZ and AU, including personal loans, credit cards, revolving credit facilities, and overdrafts. Covers the full assessment process from initial inquiry through to credit decision.

Policy statements¶

Every credit decision for a consumer credit product SHALL be based on a documented affordability assessment performed at the time of application. The affordability assessment SHALL determine whether the customer can meet repayments without substantial hardship.

The affordability assessment SHALL be performed using the governed affordability calculator (MOD-027) applied to verifiable income and expenses. The output of MOD-027 is the compliance artefact for CCCFA and NCCP Act affordability inquiry purposes.

Income used in the affordability assessment SHALL be verified against supporting evidence. Where income cannot be verified, responsible lending floor rates and conservative expense assumptions SHALL be applied. Unverified income claims SHALL not be the sole basis for approving a credit application.

A credit product SHALL NOT be approved where the affordability assessment determines that meeting the repayments would cause the customer substantial hardship. A credit product SHALL NOT be approved for a purpose that is not consistent with the customer's stated objectives and financial situation.

The affordability model parameters — including living expense benchmarks, floor rates for variable-rate products, and income haircuts — SHALL be reviewed by the CRO at least annually and updated where evidence indicates the parameters are no longer conservative enough to prevent substantial hardship.

All affordability assessments SHALL be stored immutably (MOD-002) with the credit application record. The assessment record is the legally required evidence of compliance with the affordability inquiry obligation under CCCFA and NCCP Act.

The platform SHALL not extend further credit to a customer who is currently in hardship or who has an active hardship arrangement in place, without first assessing the impact on their overall repayment burden.

Where a credit decision results in a decline, the customer SHALL receive an explanation of the general reasons for the decline upon request.

The responsible lending framework SHALL be reviewed annually and updated following any material regulatory guidance, enforcement action, or judicial decision interpreting the CCCFA or NCCP Act.

Satisfying modules¶

Module	Name	Mode	Description
MOD-027	Affordability calculator	`CALC`	Responsible lending obligation met — affordability assessment documented automatically for every application
MOD-029	Pre-approval engine	`AUTO`	Handler reads credit.affordability_assessments for the application and rejects with decision_type=DECLINE when the latest result is FAIL or absent — no code path approves a credit application without a passing affordability assessment; enforced by source-level scan and negative integration test.
MOD-050	Disclosure enforcement module	`GATE`	Responsible lending disclosure — repayment amount and total cost shown before loan acceptance
MOD-065	Credit servicing & collections	`ALERT`	Alerts the collections team when a customer misses a payment and escalates according to the collections policy timeline.
MOD-112	Amortisation schedule engine	`AUTO`	Full amortisation schedule is generated and provided to the customer at loan origination — disclosure of total cost of credit, total interest payable, and repayment schedule is automated with no manual step.
MOD-116	Mortgage servicing engine	`AUTO`	Fixed rate expiry notification at 90/60/30 days ensures customers have adequate time to make an informed rate election before reversion to variable.
MOD-117	Overdraft management engine	`GATE`	Overdraft limit cannot be set or increased without a completed affordability assessment satisfying responsible lending obligations.
MOD-121	Construction loan drawdown engine	`GATE`	Each drawdown tranche requires a completed milestone certification before funds are released — the system will not release funds based on a schedule alone.
MOD-162	Loan facility & component manager	`AUTO`	Component creation is blocked when the sum of component principals would exceed the approved facility limit — no code path creates a component outside the approved credit envelope; enforced at the handler layer and by a DB CHECK constraint.

Part of Credit Risk · Governance overview Compiled 2026-05-22 from source/entities/policies/CRE-002.yaml