XTXFX Business Plan — Governance and Team

The board, credit committee, executive team and the governance a regulated credit provider must demonstrate to the NCR.

Governance and Team

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The Regulator assesses whether an applicant has sufficient human resources to conduct the business of a credit provider. Investors should assess the same thing. XTXFX’s Year 1 structure comprises approximately fourteen full-time roles, growing to around forty-five by Year 5.

Role

Responsibility

Timing

Chief Executive

Strategy, funding, regulatory relationships

Month 1

Chief Credit Officer

Credit policy, scorecard, provisioning and collections strategy

Month 1 — the most important hire in the business

Chief Technology Officer

Platform, integrations, data infrastructure and information security

Month 1

Compliance Officer

NCR conditions, affordability governance, FIC and POPIA obligations, statutory returns

Month 1

Finance Manager

Management accounts, IFRS 9 provisioning, funder reporting and tax

Month 2

Collections Manager

Arrears operations, forbearance and external panel management

Month 4

Engineering, data science, operations and customer support

Delivery and service

Scaling from 14 to 45 across Years 1 to 5

Year 1

Year 2

Year 3

Year 4

Year 5

Headcount

14

22

31

39

45

Fixed operating costs, R million

11.0

16.2

21.6

26.2

30.0

Fixed cost per loan

R1 679

R786

R551

R456

R400

Loans per employee

468

936

1 265

1 474

1 667

Book per employee, R million

0.9

2.5

3.9

5.2

6.3

The board will comprise the chief executive, two investor-nominated directors and at least one independent non-executive director with regulated lending experience. A credit and risk committee and an audit committee will operate from Year 1, with the credit committee holding authority over policy and scorecard cut-offs independent of the commercial function.

9.2 The compliance function in detail

Compliance activity

Cadence

Owner

Evidence retained

Affordability assessment on every application

Per decision

Decision engine, automated

Every input, rule fired, score and outcome logged against the agreement

Pricing cap verification against the gazetted repo

Monthly

Compliance Officer

Ledger configuration review; caps enforced in code

Credit bureau submission

Prescribed cycle

Finance Manager

Submission files and acknowledgements

FIC customer due diligence and sanctions screening

Per customer

Decision engine, automated

Screening results and match dispositions

Debt review process handling

Per case

Collections Manager

Proposals, distributions and correspondence

NCR statutory returns and annual renewal

Periodic and annual

Compliance Officer

Filed returns and payment confirmations

POPIA data subject requests and breach response

As they arise

Information Officer

Request register and response records

Independent compliance review

Annual from Year 3

External

Review report and management responses to the board

The compliance budget rises from R1.4 million in Year 1 to R2.8 million in Year 5. Almost all of it is people and system configuration rather than external advice, because the obligations are continuous rather than episodic: an affordability assessment must be evidenced on every application, not sampled annually, and a pricing cap must hold on every agreement rather than on a policy document.

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