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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- Overview & contents
- i. Important Notice and Basis of Preparation
- 1. Executive Summary
- 2. Market Context and Opportunity
- 3. Regulatory Framework and NCR Registration
- 4. Products and Pricing
- 5. SWOT and Competitive Position
- 6. Credit Policy and Risk Management
- 7. Technology and Operations
- 8. Go-to-Market
- 9. Governance and Team
- 10. Financial Plan
- 11. Funding Structure and Capital
- 12. Break-Even and Credit Sensitivity
- 13. Sensitivity and Scenario Analysis
- 14. Risk Management
- 15. Implementation Roadmap
- 16. Investor Returns and Exit
- 17. Key Performance Indicators
- 18. Key Assumptions
- 19. Conclusion
- A. Appendix A: Consolidated Financial Summary
- B. Appendix B: Unit Economics and Volume Schedules
- C. Appendix C: Funding and Debt Schedules
- D. Appendix D: NCR Registration Checklist
- E. Appendix E: Risk Register
- F. Appendix F: Glossary
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.