Credit Supervision and Training Policy
NCCP Compliance: Credit Supervision and Training Policy
The purpose of a credit supervision and training policy is to describe the processes implemented by your business concerning the monitoring, supervision and training of its representatives. This document should be prepared in conjunction with the business’ Compliance Programme.
A credit supervision and training policy includes details of:
1. Supervision and monitoring of representatives
2. Training of representatives
3. Complaints about representatives
4. Credit representatives and Responsible Managers
Your credit supervision and training policy is one of the general conduct obligations for credit licensees. To ensure your compliance you need to test yourself against this policy regularly, document the results and take action to fix any areas of non-compliance.
QED CompliFast is an online compliance monitoring system that Australian credit licensees use to meet their NCCP compliance obligations. With different areas tested quarterly, QED CompliFast ensures adequate testing, documentation and recommended action plans for credit supervision and training policies.
ASIC Report 330 – What you need to know about managing your Credit Reps
For Credit Licensees with Credit Representatives, you may be aware that ASIC released Report 330 in March detailing how it expects Licensees to manage their Credit Representatives. In essence, the expectation now is that Licensees must:
• have risk-based systems for monitoring the activities of their Credit Representatives
• be able to aggregate monitoring results to identify possible systemic issues
• augment risk-based in-office monitoring of Reps with other types of surveillance
• be able to identify “high-risk” transactions by Credit Representatives
• be able to produce a preliminary assessment document for every loan brokered
In addition, a Licensee must be able to ensure Reps are adhering to other elements of the general conduct obligations including information security, CPD training, complaints management, EDRS membership and PI currency as well as the Rep’s use of referral sources.
The question you need to then ask is: “Are your systems and processes with your Credit Reps REALLY meeting all the above criteria?” In all likelihood, the answer is “No, they’re not.” Fortunately, QED Risk Services has the system to help you change this into a “YES!” and you’ll be shocked at how cost-effective it is.
QED CompliFastReps is an extension of our industry-leading QED CompliFast, the only complete self audit tool available for Credit Licensees, which carries our 100% ASIC-free guarantee†.
Credit Reps are required to perform their own self-audit every three months covering all their NCCP obligations to you. These results are scored and the results are able to be viewed on YOUR QED CompliFastReps dashboard. This dashboard reporting allows you to view all your Credit Reps in one place and see at a glance where there are any particular trouble spots.
To find out more call us on 1300 817 662.