XTXFX Business Plan — Appendix D: NCR Registration Checklist

The registration checklist against National Credit Regulator requirements, with responsible party and status for each item.

Appendix D: NCR Registration Checklist

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Step

Requirement

Note

1

Confirm the National Credit Act applies to the intended agreements

A substance-over-form assessment taken with legal advice, not a matter of contractual labelling

2

Incorporate the company at CIPC and adopt an MOI appropriate to a regulated credit provider

3

Register with SARS and obtain a tax compliance status PIN

4

Obtain police clearance certificates for every director, member, trustee, partner or shareholder

Required for all controllers without exception

5

Confirm no director or controller is disqualified under the Act

Including by reason of unrehabilitated insolvency

6

Prepare company letterhead showing registered name, address, contact person, telephone and email

7

Prepare evidence of adequate human, financial and operational resources

Organogram, curricula vitae, financial projections and systems description. The capacity assessment

8

Draft the credit policy, affordability assessment methodology and pre-agreement documentation

For submission and review

9

Complete and submit Form 2 with all annexures and pay the application fee

10

Pay the registration fee, scaled to anticipated principal debt, and the branch fee for each premises

From approximately R1 000 where principal debt is under R250 000, plus roughly R250 per location

11

Register with the Financial Intelligence Centre as an accountable institution

Adopt a Risk Management and Compliance Programme

12

Appoint and register the Information Officer with the Information Regulator, and publish the PAIA manual

13

Establish reporting arrangements with at least one registered credit bureau

14

On receipt of the certificate, display the registration number on all agreements, quotations, advertising and correspondence

15

Diarise annual renewal, statutory returns and the conditions of registration

Recurring board-level obligations, not once-off hurdles

Registration cost item

Indicative cost

Application fee

Payable on submission of Form 2

Registration fee, scaled to total principal debt

From approximately R1 000, rising with book size

Branch fee, per location

Approximately R250 per location

Company formation, MOI and letterhead

Included in formation cost

Police clearance certificates

Per person, for every controller

Professional support with the application

Approximately R6 000 to R15 000