Collections & Hardship Policy¶
| Code | CRE-007 |
| 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)¶
Purpose¶
Govern the platform's approach to managing delinquent accounts, collections activities, and financial hardship requests. Ensures collections and hardship management is conducted fairly, compliantly, and in a manner that prioritises customer outcomes while managing credit losses within the risk appetite.
Scope¶
All credit accounts that are 1 or more days past due, or where the customer has requested financial hardship assistance, in NZ and AU. Covers early arrears management, collections activity, hardship assessment and arrangement management, and the interface with enforcement and default processes.
Policy statements¶
The platform SHALL contact a customer whose account is 7 or more days past due within 5 business days of the account reaching that status. Initial contact SHALL seek to understand the reason for arrears before escalating to formal collections activity.
A customer who contacts the platform requesting financial hardship assistance SHALL receive an acknowledgement within 1 business day. A hardship decision SHALL be communicated to the customer within the timeframe required by CCCFA (NZ) and NCCP Act (AU).
Where hardship assistance is granted, the account SHALL be placed in a hardship-protected state (MOD-007) immediately. The hardship-protected state SHALL prevent: automated collections contact, automated fee capitalisation beyond the agreed arrangement terms, and credit bureau default listing while the arrangement is current and performing.
Collections activity SHALL be conducted in a manner consistent with CON-001 (Customer Fairness) and CON-003 (Vulnerable Customer Policy). Contact frequency, timing, and communication approach SHALL comply with the applicable banking code and telecommunications legislation.
No enforcement action — including issuing a default notice, commencing legal proceedings, appointing a receiver, or listing a default with a credit bureau — SHALL be taken while a hardship application is pending or while a current hardship arrangement is performing.
Where a hardship arrangement is not performing — defined as two or more consecutive missed arrangement payments — the case manager SHALL contact the customer to discuss options before enforcement action is considered.
All hardship applications, outcomes, arrangement terms, performance records, and case manager notes SHALL be recorded in the case management system (MOD-053). Records SHALL be retained for 7 years.
The collections and hardship programme SHALL be reviewed at least annually and benchmarked against industry outcomes, regulatory expectations, and complaint data from MOD-053.
The Head of Credit Risk SHALL report hardship volumes, arrangement performance rates, and collections outcomes to the Board Risk Committee quarterly.
Satisfying modules¶
(No modules assigned yet — manual process)
Part of Credit Risk · Governance overview
Compiled 2026-05-22 from source/entities/policies/CRE-007.yaml