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Three Year AnnualPerformance Plan

Five Year Strategic Plan2018/19 - 2020/21

2018/19 - 2022/23

Three YearAnnual Performance Plan2018/19 - 2020/21

4 | National Credit Regulator - 3 Year Annual Performance Plan 2018/19 -2020/21

AA - Accounting Authority

ARMC - Audit and Risk Management Committee

ADR - Alternative Dispute Resolution

CB - Credit Bureau

CCI - Consumer Credit Index

CCMR - Consumer Credit Market Report

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COTII - Council of Trade and Industry Institutions

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CP - Credit Provider

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dti - Department of Trade & Industry

DPSA - Department of Public Service Administration

EXCO - Executive Committee

FSRA - Financial Sector Regulation Act

ICT - Information Communication Technology

MICTSETA - Media Information and Communication Technologies Sector Education and Training Authority

NCA - National Credit Act

NCAA - National Credit Amendment Act

NCR - National Credit Regulator

NCT - National Consumer Tribunal

PDA - Payment Distribution Agents

PFMA - Public Finance Management Act

SADC - Southern African Development Community

SDIP - Service Delivery Improvement Plan

SMME - Small Medium and Micro Enterprises

WRSETA - Wholesale and Retail Sector Education and Training Authority

Effective - Successful in producing a desired or intended result

Enhance - Improve the quality of performance

Support - To give assistance

Facilitate - To make an action or process easier

Abbreviations

Definitions used to measure performance

1. NCR Organisational structure ..................................................................................................... 7

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3. Foreword by the Minister.............................................................................................................. 9

4. Overview by the Accounting Authority ....................................................................................... 11

PART A: Strategic Overview ........................................................................................................... 16

5. Vision .......................................................................................................................................... 16

6. Mission ........................................................................................................................................ 16

7. Values .......................................................................................................................................... 16

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9. Strategic objectives ..................................................................................................................... 17

10. Services ..................................................................................................................................... 17

11. Recent Court Rulings ................................................................................................................ 17

12. Situational Analysis ................................................................................................................... 20

State of the Credit Market ................................................................................................. 20

a) Certainty in the regulatory framework ........................................................................... 21

b) Increasing complexity and sophistication ...................................................................... 21

c) Stakeholder management .............................................................................................. 21

d) Challenges faced by the NCR ........................................................................................ 21

a) Processes, system and structure renewal ....................................................................... 22

b) Human Capital ............................................................................................................... 22

c) Knowledge intensity ....................................................................................................... 22

Strategic Alignment to the dti ........................................................................................... 22

13. Description of the Planning Process ......................................................................................... 23

14. Financial Plan ............................................................................................................................ 23

(i) Projections of revenue, expenditure, borrowings and capex ......................................... 24

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(v) Dividend policies ........................................................................................................... 26

Table of Contents

National Credit Regulator - 3 Year Annual Performance Plan 2018/19 - 2020/21 | 5

PART B: Programme Performance ................................................................................................. 27

15. Programme 1: ........................................................................................................................... 27

16. Programme 2: ........................................................................................................................... 33

17. Programme 3: ........................................................................................................................... 35

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19. Programme 5: ........................................................................................................................... 41

PART C:��L��??

3.1 Fraud Prevention Plan: .............................................................................................................. 44

3.2 Key Strategic Risks .................................................................................................................... 47

4. Any subsidiary of statutory body reporting to the entity ............................................................ 51

5. Service Delivery Improvement Plan ............................................................................................. 51

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1. NCR Organisational Structure


CEO and AA

CFO

Manager:Investigations &

Enforcement

Manager:Compliance CB

Manager:Compliance CP

Manager:Registrations

Manager: Debt Counselling

Manager:Education &

CommunicationManager: HR

Manager: Statistics &

Research

Manager:Call Centre

Manager:Complaints

CompanySecretary

COO (Vacant) Deputy CEO

OutsourcedInternal Audit ARMC

EXCO

Management Team

2. Official sign-off��

• Was developed by the management of the National Credit Regulator under the guidance of Mrs N Motshegare, who is the CEO and Accounting Authority.

• Was prepared in line with the current Strategic Plan of the National Credit Regulator.

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3. Foreword by the MinisterW�� +��"� �^� ��"�after the National Credit Regulator’s (NCR’s) tenth year anniversary, we are reminded once more about our purpose to continue to strengthen consumer protection in the consumer credit industry while facilitating the sustainability and continued development of the credit industry.

U�� _�� [#�^� `�� z��"� {��L|�� Global Economic Prospects report provided an outlook for potential growth in each of the six global regions. “In Sub-Saharan Africa: Growth in the region is anticipated to pick up to 3.1 percent in 2018 from 2.4 percent in 2017. South Africa is forecast to pick up to 1.1 percent growth in 2018 from 0.8 percent in 2017.” (Source: The World Bank: Press Release dated 9 January 2018: Global Economy to Edge up to 3.1 percent in 2018 but Future Potential Growth a Concern).

The South African forecast is also supported by data released by Statistics South Africa. The economy of South Africa was reported to be on a recovery path. The economic activity in Q3 rose to 2.0% quarter-on-quarter- (Source: Focus Economics, December 8, 2017).

This showed that the economy was gaining traction post the recession in Q2. Unemployment in South Africa still remains a challenge though.The unemployment rate was recorded at 27.7 ��^��"��"��"�� 2017 - the highest rate in 13 years, according to Trading Economics.

In terms of the TransUnion Consumer Credit Index (CCI), consumer credit health improved (albeit marginally), even though there was a slight decline in Q3 in 2017 at 53.9%, from Q2 in 2017 at 54.1% (an index level of 50 is considered the �+��L��|� ��^� ;�� ;�� :��worsening credit health).

The results of the index were reported during a dire period of challenging economic conditions ��"��;��>��;��Q� ��*��]�(Source: Southern Consumer Credit Health “No room for complacency”, 20.11.2017).

A similar trend was reported in the Credit Bureau Monitor published by the NCR. The report is based on consumer credit data held by registered Credit Bureaus.

Consumers considered to be impaired were J��/�� GJ�G$�� 8�[�� /�� "��active consumers as at end September 2017 (Q3). This was an increase from Q2 at 9.69million or 39.1%.

Dr Rob Davies, MPMinister of Trade and Industry


Year-on-year since September 2015, however, there was an improvement in the percent of impaired consumers - 2015: 42.3%; 2016: 40.6%; 2017: 39.36%.

A consumer is classified as impaired if at least one account is three or more months in arrears, or has adverse listings, or has a judgement or administration order. The sluggish economic growth, high unemployment, consumer over-in-debtedness and uncertainty in a volatile global economy all place consumers under intense pressure and risk.

The National Credit Act No 34 of 2005 (the Act) as amended is a Government legislation enacted to amongst others, promote and advance the social and economic welfare of South Africans, promote a fair, transparent, responsible and accessible credit market and industry and to provide for consumer protection.

The Act established the National Credit Regulator (the NCR) which commenced operations in 2006. In order to deliver on the above legislative mandate, the NCR developed five (5) Key Strategic Objectives for the period �[#�\#J�]��[�[\�#�

The NCR objectives are aligned to the Key Policy Areas of the Department of Trade and Industry, the National Development Plan, theMedium Term Strategic Framework and the Nine Point Plan and require the NCR to; Promote responsible credit granting, Protect consumers from abuse and unfair practices and address over-indebtedness; Enhance the quality and accuracy of consumer credit information; Improve NCR’s operational effectiveness; and Facilitate efficient registration of persons and entities to include those involved in consumer credit operating underground to be formalised.

Government has considered it necessary to develop a statutory mechanism to assist low income over-indebted consumers who falter;through debt counselling and the personal insolvency regime.

Therefore, in addition to the above work, the NCR will continue to participate in discussions relating to the Debt Intervention Bill introduced by the Portfolio Committee on Trade and Industry.

It is anticipated that the NCR will be one of the implementing agencies for debt intervention so that more over-indebted consumers are rehabilitated and given an opportunity once more to participate in the consumer credit industry and mainstream economy.

In spite of the challenges that the NCR may continue to face in the future, I am confident that the NCR will possess the resolve and resilience to overcome these challenges and will, therefore, deliver on its mandate.

I am pleased to release its 3-year Annual >��/�� >�� [#�\#J� �� [�[\�#� ��"�� 8�� Q�� >�� [#�\�[#J� ��[��\�G� ;�� "�� ;� �+<�� ;�� +�met with the continued support of the dti.



4. Overview by the Accounting Authority

The past year marked the tenth anniversary of the National Credit Regulator (NCR) which coincided with the events that started the global financial crisis and the world has changed significantly since then.

This calls for the need for cooperation with other key stakeholders, including regulators, locally and internationally and acting more proactively and effectively, to identify and address market problems. Consumer expectations have changed and they have become more empowered. We now live in an era where technology and social media are at our fingertips. Regulatory technology has to be developed and leveraged to enhance the NCR’s reach, impact, and effectiveness. Every consumer now has unprecedented access to information and it is, therefore, necessary for business and regulators to step up and respond accordingly.

The NCR is committed to continuing to build a consumer credit market that works for consumers, the credit industry and for the South African economy. A desire for fair access to legitimate credit, an alternative to abusive credit practices, and high quality service must remain the hallmark of the credit industry.

As a regulator, it is important to use our mandate to act more efficiently to identify andaddress market problems. We need to ensure that consumers receive fair, transparent and responsible access to credit while educating consumers to make sound financial decisions for themselves. The current economic climate in South Africa is slowly improving, which means that consumers will be in better shape to weather economic storms. There are promising signs that the consumer credit market is poised to perform well in 2018. The economy grew by 2.0% in the three months to September 2017.

This is in line with growth in Sub-Saharan Africa which is estimated to have rebounded to 2.4% in 2017 from 1.3% in 2016. The projections are that regional growth will rise to an average �� G�$�� [#J\�[� �� (article on Sub-Saharan Africa, by Gerard Kambou – Global Economic Prospects, January 2018).

High unemployment, however, remains a major social challenge and if this is not addressed, it will result in decreased household consumption. The priorities of the NCR are aligned with the Key Policy Areas of the Department of Trade and U�" �� %"��'� �� [#�\#J� �� ̂ � ��National Development Plan, the Nine Point Plan and the Medium Term Strategic Framework.

Nomsa MotshegareAccounting Authority


These focus areas reflect the NCR’s vision of promoting a South African consumer credit market which is fair, transparent, accessible and contributing to South Africa’s socio-economic development. The NCR operates under the ambit of the National Credit Act No 34 of 2005 (the Act) as amended. A high level situational analysis conducted identified trends in the developments that are likely to influence the consumer credit industry and impact the NCR over a period of time. The factors impacting on the regulatory environment include the following:

!�� (�� ) According to the NCR Consumer Credit Market Report and Credit Bureau Monitor which cover credit market information up to September 2017, ��"�� + �� "� ��"�� 8�[�� /��credit-active consumers for the quarter ended September 2017, an increase of 0.32% when compared to the 24.25 million in the quarter ended September 2016.

The number of consumers classified in good standing increased by 115,000 to 15.21 million. The percentage number of consumers classified in “good standing” accounted for 60.64% of the total credit-active consumers. This was an increase of 1.26% year-on-year. One of the most significant trends observed in terms of credit granted for the quarter ended September 2017 is that the total outstanding consumer credit balances (or gross debtors’ book) was R1.73 trillion, representing a year-on-year growth of 3.44%.

The above consumer credit insights will help us guide our strategy and planning going forward. They indicate that although consumercredit health is improving, consumers remain credit stretched. These trends are supported by the Consumer Credit Index (CCI) published by TransUnion. The index “measures” the aggregate consumer loan repayment record, tracks the use of revolving consumer credit facilities as an indicator of distressed borrowing, estimates household cash flow and quantifies the relative cost of servicing outstanding debt.

These aspects are then combined into a single indicator of credit health” (TransUnion Q3 2017 Consumer Credit Index Report). The CCI dropped slightly to 53.9 in Q3 from 54.1 in Q2, but because it remained above 50.0 (where 50.0 is the breakeven point), this is an indication of some improvement in consumer credit health.

In an article titled “Bad Debts better than a year ago, but the picture for this year is mixed” by Tammy Foyn, dated 17 August 2017, it is reported that bad debts for South Africans improved compared to the previous year and that indebtedness of households has been easing. Household debt to disposable income ratio as ��"� �� +� �� [�� [#G� ��"� �� ;��reduced to 75% for Q2, 2016 and further reduced to 74% for Q3 of 2017.

`�� [[�� ""� �� /� �� %Q� ��@� { �� ]� �`�� biggest risks every South African household faces in 2017”, January 2017) enforcing federal consumer financial laws and protecting consumers in the financial marketplace.

Despite improved consumer credit health, consumers are still not out of the woods. Measures will have to be identified to continue to improve consumer credit health by preventing financial harm to consumers while promoting responsible and sustainable lending practices that benefit them.

*��(��)�The Credit Industry Forum continues to provide a neutral platform to discuss cooperation between various industry associations to find solutions to industry challenges in the credit industry. The NCR will also continue to engage on a regular basis with other local and international regulators such as the South African Reserve Bank, Financial Services Board, the Competition Commission, and the Consumer Financial Protection Bureau in the United States. The main function of the Bureau is to enforce federal consumer financial laws and protect consumers in the financial marketplace.


NCR, therefore, collaborates with other regulators to share guiding principles and best practices. In terms of the National Credit Act, as amended, and the Financial Sector Regulation Act, 9 of 2017 (FSRA), which will implement the Twin Peaks model for financial regulation and supervision, the NCR will cooperate with regulators to be established under the FSRA.

The NCR participates in quarterly regulatory cluster meetings of the Council of Trade and Industry Institutions (COTII) which facilitate sharing of information and pulling resources to work together as regulators. The regulators who form COTII all report to the dti.

Collaboration regulation is about having a holistic view of the regulatory environment and an inclusive dialogue across sectors. It is important for sharing of information and experiences in terms of best practices in different regulatory aspects.

��$��)�The NCR working jointly with local Tribal Authorities in rural areas of most provinces, will conduct community outreach programmes (“Imbizos”) aimed mainly at pensioners to create awareness relating to their rights and responsibilities as consumers in the credit industry.

The NCR will continue to focus on visits to rural areas as most consumers in the credit market who reside in these areas form part of the vulnerable communities that must continue to be protected from financial harm. NCR will empower consumers in general by assisting them to understand the costs and risks of financial decisions, build trusted relationships that are informative so that they can make better informed choices and live better financial lives.

$��) This ensures compliance with the Act and enforcement of the Act to hold violators accountable by utilising a range of compliance monitoring and enforcement tools. A full update on matters before the National Consumer Tribunal and the courts are in the section on “Recent Court Rulings’’.

The enforcement of the Act is one of the key functions of the NCR. This is primarily done through conducting investigations. These investigations are informed by complaints from consumers, trends identified in the media, referrals from other institutions and compliance monitoring.

�� #�� ) As a result of the prudent financial management and corporate governance practiced, the NCR has always obtained an unqualified audit opinion and aims to achieve a clean audit opinion going forward. To this end the NCR holds regular engagements with Assurance Providers (Internal and External Auditors) through combined assurance forums. It is also important for the NCR to effectively and efficiently deliver on its mandate.

A service delivery improvement plan is being developed and will be implemented from �� [#�\#J� �� z� �� financial challenges encountered in executing the planned strategic activities. To achieve the long-term goals, we will need to ensure that the strategic plan is robust. Management will need to be flexible and alert to new opportunities as they present themselves.

The NCR has continuously been focusing on measures to cut operational costs and simultaneously identifying other revenue streams to deal with funding challenges. For example, some of the work that was outsourced has been internalised by providing extensive training to staff. Some of the NCR legal advisors have been empowered to refer and defend matters at the Tribunal.

Measures that have been identified to supplement income include the following: to submit a proposal to the dti to increase registration fees; the PDA interest utilisation policy has been reviewed and a proposal has been submitted to the dti to utilise the PDA interest earned for additional purposes that will in the long run benefit consumers e.g. research and impact studies.


The NCR is committed to good governance practices. It complies with the prescripts of the Public Finance Management Act (PFMA) and Treasury Regulations.

The responsibilities of the Accounting Authority vest in the Chief Executive Officer. An Audit and Risk Management Committee (ARMC) is constituted in terms of the PFMA and Treasury Regulations. The Internal Audit function, which reports to the ARMC, is outsourced. The organisation has been working smartly to achieve most of the objectives it set out to meet. By the end of September 2017 (second � �� [#�\#�� '^� #[[�� the planned quarterly milestones had either been achieved or exceeded for two quarters. This needs to be maintained going forward.

*�� [#�\#J�;�� "��following: Education and awareness campaigns on deceptive and unfair practices, and consumer rights; Monitoring and enforcement programmes in particular in relation to the new registrants.

The National Credit Amendment Act and its Regulations make provision for all credit providers to be registered with the NCR and the threshold has been reduced to R1,00; Monitoring and enforcement programmes in relation to collection and sale of prescribed debts and credit providers to be encouraged to refrain from doing this; Monitoring the implementation of the Affordability Assessment Regulations; Review of the cost of credit and credit life insurance; and improved publication on the work undertaken by the NCR and its success stories.

We have aligned the key performance areas with the strategic objectives and core themes of the dti. The vision and mission are articulated through strategic goals. Measurable performance indicators as well as an analysis of external and internal factors that could affect the ability to achieve our goals are indicated. Strategic risks, which we could be exposed to, as well as possible mitigating controls, are also identified.

The strategic thrusts driving the plan include: - To promote responsible credit granting, to protect consumers from abuse and unfair practices in the consumer credit market and address over indebtedness; to enhance the quality and accuracy of consumer credit information; to improve NCR’s operational effectiveness; and to facilitate efficient registration of persons and entities.

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A Debt Intervention Bill was introduced by the Portfolio Committee on Trade & Industry and published in November 2017 for public comment. The Bill seeks to bridge the gap between low income consumers who cannot afford to go under debt review, and those who do not have any income and assets.

There is currently no legislative mechanism to assist this category of consumers in the current legislative framework. It is anticipated that the NCR will be one of the implementing agencies of this Bill once enacted. Implementation of the {��/��//��[#�\#J��

NCR will need to be capacitated to be able to deliver effectively on this Bill. Deadline for submission of written comments by the public �� {�� ;�� #8� _�� [#�� `�� >��Committee has commenced with public hearings regarding the Bill.

I would like to thank the NCR Executive Team, Management and personnel for their efforts, energy and dedication in providing a valuable contribution in the development of the consumer credit market.

This has assisted the NCR to make strides in achieving its strategic goal of protecting consumers in the country. The continued dedication and passion displayed by the NCR employees will go a long way in making a difference in the lives of many vulnerable communities in South Africa.


My gratitude is also extended to the dti in advancing socio-economic development in the country. The NCR will strive to improve its efficiency and effectiveness in the implementation of the Act and protection of consumers.

I am grateful to the Honourable Members of the Portfolio Committee on Trade & Industry, the Honourable Members of the Select Committee on Trade and International Relations, the Honourable Minister of Trade and Industry, Dr Z�+� ��^� �� ^� !�� October, the Group Chief Operating Officer, Ms Jodi Scholtz, and the Acting Deputy Director-General, Mr MacDonald Netshitenzhe for their guidance and continued support of the NCR.

I would also like to extend my sincere appreciation to the Members of the Audit & Risk Management Committee, for their dedicated energies and time they devote to the NCR.



Part A: Strategic Overview2. Vision

The vision of the NCR is:

“To promote a South African consumer credit market that is fair, transparent, accessible and dynamic.”

3. Mission

The mission of the NCR is:

�̀�� "��/��"��/��Q� ��*��^�+�@]� • regulating for a fair and non-discriminatory market for access to consumer credit; and • promoting responsible credit granting, use and effective redress.

4. Values

The values of the NCR are:

Service ExcellenceWe strive for service excellence that exceeds the expectations of all stakeholders.

Integrity We are committed to honesty and integrity without compromise.

Empowerment We strive for empowerment in the consumer credit market and we are also committed to employee empowerment.

Good Corporate GovernanceWe strive to be a model of good corporate governance at all times.

5. Legislative Mandate

The legislative mandate of the NCR is as follows:

• To promote a fair and non-discriminatory marketplace for access to consumer credit and for that purpose to provide for the general regulation of consumer credit improved standards for consumer information; • To prohibit certain unfair credit and credit market practices; • To promote responsible credit granting and use and for that purpose to prohibit reckless credit granting; • To provide for debt re-organisation in cases of over-indebtedness; • To regulate credit information; and • To promote a consistent enforcement framework relating to consumer credit.


6. Strategic objectives

The strategic objectives the NCR pursues are as follows:

1. To promote responsible credit granting.2. To protect consumers from abuse and unfair practices in the consumer credit market and address over-indebtedness.3. To enhance the quality and accuracy of credit bureau information.4. To monitor and improve NCR’s operational effectiveness.5. To facilitate effective registration of persons and entities.

7. Services

The NCR renders the following services, in accordance with the requirements of the NCA.

• Register credit providers, credit bureaux, PDAs, ADRs and debt counsellors, and monitor their compliance with the Act. • Educate and create awareness of the protection that the NCA offers; • Research the credit market and its trends, monitor access to credit and the cost of credit to identify factors that may undermine access to credit, competitiveness in the credit market and consumer protection; • Advise government on policy and legislation; • Receive and investigate complaints and ensure that consumer rights are protected and • Enforce the NCA and take action against contravening entities.

8. Recent Court Rulings

Matter Name Court & Case Reference No. Legal issues and status

Truworths and others vs NCR and dti

Western Cape High Court Case No: ?G�8\#$

This is a High Court review of the affordability regulations by the clothing retailers. The matter ;�� "� �� ^�� "� #[� * � �� [#�� "� ;� �;��judgement.

MFSA vs NCR and dti North Gauteng High Court Case No: #$�?$\#$

This is a High Court review of Regulation 42- limitation on fees and interest by MFSA in which the matter was ruled in favour of MFSA and the NCR and dti have launched an appeal which was heard on 12 and 13 December 2017 and we await judgement.

MFSA vs NCR, dti and NCT

North Gauteng High Court Case No: $?$?$\#$

This is an application for a Declaratory Order regarding the interpretation of section 102 that was brought by the MFSA. MFSA would like the court to interpret the section as permitting for the inclusion of initiation fees into the deferred amount for all types of credit agreements, and not just the credit agreements mentioned in section 102. The parties are still exchanging pleadings and as soon as the pleadings have closed the matter will be set down for a hearing.


A brief summary of recent court cases and rulings are provided below:


Bridge Corporate (Pty) ��"��Y�Z

North Gauteng High Court Case No: ��$�\#?

`�� {��"�� %>��'� ��"� �� "� �� High Court for an order to declare sections 55 and 57 of the NCA, which grant the NCR powers to issue compliance notices, unconstitutional. The matter is � ��""� ��"�� "��{��"��%>��'��"�

Bayport vs Minister of Justice and NCR

North Gauteng High Court Case No:��$J\�[#?

Bayport brought an application to declare consent to foreign jurisdiction as legitimate, in spite of the express prohibition in Section 90(2)(k)(vi) (bb) of the NCA. We await a date of set down for the matter to be heard.

SAFPS vs NCR and NCT North Gauteng High Court. Case No: $$[\�[#$*

This is an appeal by SAFPS against the decision of the NCT that found SAFPS guilty of prohibited conduct and for breaching the NCA regarding retention periods of adverse listings for credit bureaus. On 30 November 2017 the North Gauteng High Court upheld the appeal by SAFPS. The NCR is appealing the High Court decision in the Supreme Court of Appeal.

NCR vs Finbond National Consumer�̀�+ ��Y�`\�$$�J\

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The NCR referred Finbond to the NCT for charging consumers unreasonable cost of credit life insurance. The matter was heard on the 25th July 2017 and the NCT dismissed the NCR’s case. The NCR is appealing the decision.

�;��Q��/��"��NCR and NCT

North Gauteng High �� @�*$J?\#$

`�� +��;�� "��Y�`� �� "�� ;�� +��"�conduct for the mis-selling of credit life insurance. `��/��"�;��!��[#��

NCR vs Shoprite Investments

National Consumer�̀�+ ��Y�`\G�J?$\

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The NCR referred Shoprite to the NCT for allegations of reckless lending and mis-selling of credit life insurance. The matter was heard on the 20 June 2017 and the NCT ruled in favour of the NCR and found Shoprite � �� L�� "�� *� �� Z#� [[[� [[[� ;��imposed. Shoprite has appealed the decision and the NCR is opposing the appeal.

Getbucks (Proprietary) ��/��"��Y�Z��"�Another

North Gauteng High Court Case No: �[#88\#8

��+ �L�� %>��'� ��/��"� ��"� �� Court to declare Regulation 44 ultra vires and void and to seek declaratory relief regarding the process to be followed when NCR investigates complaints in terms of section 136(2). The parties are still exchanging pleadings and once the pleadings have closed, the matter will be set down for a hearing.



Moneyline Financial Q��%>��'��"��NCR

*??\#$ Moneyline has appealed the decision handed down by the NCT which ruled that the NCR acted lawfully and procedurally correct when investigating Moneyline. The merits of the matter relate to allegation of reckless lending towards the recipients of social security grantsby Moneyline. The matter was set down for a hearingon 6 December 2017 and it was postponed on accountof Moneyline not being ready to proceed. We now await a new date for the hearing.

NCR vs Diners Club SA and Std Bank

??��8\#$ This is an application by the NCR for an order declaring that the Diners Club agreement concluded with consumers, which is administered by Standard Bank on behalf of Diners Club SA, is a credit agreement as "��"� �� %?'�� *��`��/��;��+��"��#?�!��[#��

NCR vs Standard Bank North Gauteng High Court Case No: ???#8\#$

The NCR has brought an application for a declaratory order regarding the application of the common law principle of “set off” on credit agreements. Once all the pleadings have been exchanged between the parties, the matter will be set down for a hearing.

�"��"��"��NCR

North Gauteng High Court Case Case No: *�G�\�[#�

The NCR referred Edcon Group to the NCT for the unlawful charging of club fees to consumers, and the NCT ruled in the favour of the NCR. Edcon has launched an appeal against the decision of the NCT. The matter ;��+��"��#8�!��[#��

Y�Z��;��Q��%>��'��"

National Consumer�̀�+ ��Y�`\?#$�#\

�[#$\#?[%#'

`�� Y�Z� ��"� �;�� Y�`� �� ; ��charging of club fees to consumers, and the NCT ruled �� ;��`��Y�Z�� "��against the decision of the NCT. The matter is set down ��#?�*��[#��

NCR vs Wesbank a division of First Rand {��L��/��"

National Consumer�̀�+ ��Y�`\��[[\

�[#�\#?[%#'

The NCR referred Wesbank a division of FirstRand {��L��/��"��Y�`��;��Wesbank’s debt collection practices, which revealed that Wesbank does not allow consumers to voluntarily surrender their motor vehicles, in contravention of Section 127.



NCR vs Standard Bank National Consumer�̀�+ ��Y�`\�J[?#\

�[#8\#?[%#'

The NCR referred Standard Bank to the NCT for reckless lending. The matter concerns the so called “699 Satinsky car scheme”. The NCT dismissed the application by the NCR and the NCR is appealing the decision.

NCR vs Nedbank National Consumer�̀�+ ��Y�`\G#$�[\

�[#8\#?[%#'

The NCR referred Nedbank to the NCT for reckless lending. The matter concerns the so called “699 Satinsky car scheme”. The hearing was set down for �J�_�� [#��U��"�"��;��"��"�;��postponed to a soon to be decided date.

BMW Financial Services %Q*'�%>��'��"��Y�Z

National Consumer�̀�+ ��Y�`\G#$�[\

�[#8\#?[%#'

A compliance notice was issued for the “on the road” fees. BMW has objected to the compliance notice by an application to the NCT. The NCR is opposing the ��"��"��;��"��{!z|��"��;��+��"��"��"��" �� ^�whereafter the matter will be set down for hearing.

Volkswagen Financial Q��%Q*'�%>��'��"��NCR

National Consumer�̀�+ ��Y�`\JG��J\

�[#�\8$%#'

A compliance notice was issued for the “on the road” fees. VW has objected to the compliance notice by application to the NCT. The NCR is opposing the ��"��;��"��

9. Situational analysis

*��/��;�� "��L��"��/��"��/��"�� /�� L�� : �� /�� Y�Z�� ^� ��brief synopsis of the state of the credit market is provided. An analysis of the internal and external factors impacting on the NCR is then provided.

State of the Credit Market

`�� "��"� �� ;��/��"��Q��/+��[#��/� ��"� ��Z?�G�8��+��/��"��Z?8��G#�+��/��"��[#$��`�� "��"+��|�+��L�increased by R57.44 billion (3.44%) for the quarter ended September 2017, when compared to the quarter ended September 2016. The value of the debtors book at the end of September 2017 was R1.73 trillion ��G��#��/��

For the quarter ended September 2017, the total rand value of new credit granted was R123.64 billion, with Mortgages comprising R37.54 billion (30.36%), Secured Credit R42.25 billion (34.17%), Unsecured Credit Z��J�+��%#��[G�'��"��"��Z#$�#G�+��%#G�[8�'�

Applications for registration of credit providers are steadily increasing. A total of 6 599 credit providers with 36 959 branches, 23 Credit Bureaus, 3 Payment Distribution Agents, 4 Alternative Dispute Resolution *��"�#�?�8�"+�� ;��"�;��Y�Z��G#�_�� [#��/��;��"��+��"��/��^��"��"�� whilst unregistered.


Performance Delivery Environment (external)

`��;��"��/��;��"��"��L��"�� L��work of the NCR:

a) Certainty in the regulatory frameworkUncertainty in the regulating enforcement can curb job creation. Regulatory certainty creates consistent application of the legislation resulting in desirable outcomes that have a positive impact on the credit /��L��"�� /��/��"��"��+��

The NCR has worked closely with the dti to close the gaps that existed in the legislation through the Y��"��*/�"/��*��Y��#J��[#?��"�� @��*��"�+��*��/��^��"��Insurance, Interest rates and fees; Requirements to register every person and entity that extends credit. Implementation of the regulations has commenced and will be closely monitored. Impact of these regulations will be conducted in the next 3 years.

b) Increasing complexity and sophisticationThe evolution of the credit market has come with innovation by the industry. This continues to increase alternative consumer lending. The emergence of on-line, peer-to-peer lending and other new forms of lending in South Africa and other countries has brought new regulatory challenges. Close monitoring or scrutiny on compliance with the law will have to be done.

The NCR is also closely monitoring the introduction of the new credit products and the advertising methods of credit providers in order to curb the luring of consumers into debt traps. This in turn requires improved product knowledge and understanding by the NCR to be able to monitor their compliance with legislation effectively.

c) Stakeholder managementThe approach of the NCR towards stakeholder management is to facilitate open discussion and engagement with the industry and other stakeholders. Efforts are being made to achieve this objective while avoiding regulatory capture by the industry.

The NCR has established the Credit Industry Forum which serves as a platform for the NCR and industry to engage and reach agreement on industry issues. The forum represents all industry players and consumers. It plays an important role in resolving operational problems on the implementation of the legislation. The forum continues to meet quarterly and several guidelines and circulars have been issued to the industry emanating from these meetings. The NCR is a member of the African Consumer Protection Dialogue which is facilitated by the Federal Trade Commission of the United States (The African Dialogue). This forum brings together regulators from all over the African continent to discuss consumer protection issues and share information. NCR will continue to participate in conferences arranged by the African Dialogue.

The NCR also holds regular meetings with industry associations, registrants and magistrates. ��/��"�;��"��;�� "�other regulators including the Reserve Bank of South Africa.

The NCR has also established networks with other regulators in the SADC region, United States of America and the United Kingdom. More relationships will be established with other regulators across the globe.

d) Challenges faced by the NCRThe main challenge of the NCR is funding. The NCR requires additional funding to meet its operational requirements.

`��Y�Z�� "��;�� /��+ "��"��+��+�� mandate.


Organisational Delivery Environment (Internal)

`��;��"��/��;��"��"��L�� L��;��L��NCR:

a) Processes, system and structure renewalA new human resource management system and a performance management system have been introduced.

b) Human CapitalThe NCR is focusing on staff issues and ensures that staff morale remains high. In order to increase capacity ��Y�Z�� " ��/��*�"��"��;�Q��

c) Knowledge intensityIn order to provide guidance to stakeholders and employees on the developments and trends in the credit market, the NCR relies on measures such as issuing public notices, capacity building workshops, media statements, radio and TV interviews, community outreach programmes (Imbizos) and others. The NCR also publishes statistics on a quarterly basis on the level and nature of consumer indebtedness. In-house training sessions are provided for staff.

Strategic Alignment to the dti

`��"��^��Y�Z|��/��̂ �� /�� /�?�]��Employment through Inclusive Growth. In aligning its strategic priorities, the NCR took into account the external and internal environmental trends and issues as well as priorities of government which are the twelve (12) outcomes, NDP and the Nine Point Plan.

*��+��"��̂ ��;�� /��"��/��L��/��^��for ensuring inclusive growth and employment creation. Thus, the activities of the NCR are most closely associated with contributing to Outcome 4. The alignment between the outcomes that the NCR seeks to achieve, the strategic objectives of the dti, its strategic outcome oriented goals, the NDP and the Nine Point Plan is set out below:

The Nine Point Plan includes “unlocking the potential of SMMEs, Cooperatives, townships and rural ��||�� ̀� �� "^� Y�Z� �� /�� "� �/�� +�� " ��turnaround times to register new entrants (persons & entities). This will result in increased job creation.

dti Objectives dti Outcomes NCR Objectives NCR Outcomes

Grow the manufacturing sector to promote industrial development, job creation, investment and exports.

Facilitate the transformation of the economy to promote industrial development, investment, competitiveness and employment creation.

• To promote responsible credit granting.• To enhance the quality and accuracy of consumer credit bureau information.

• Reduced levels of over-Indebtedness.• Affordable levels of credit promoted.• Improved quality and accuracy of consumer credit information.


10. Description of the Planning Process

`��+��;�� //��;��/��the organisational strategic direction. The dti, Audit and Risk Management Committee and Internal Audit play a pivotal role in that they review and provide inputs to the process. Workshops are then held between executive members and the management team to develop the departmental operational objectives.

Management in turn engages with their respective team members to develop operational objectives which are in line with the business plan of the organisation. Upon approval of the strategic and operational objectives, all employees including executive management conclude performance contracts annually.

11. Financial Plan

��"�"��L�� Y�Z��z��/��"�� ^�and the need to regulate the credit industry and enforce the NCA, it is imperative for the NCR to optimise the available funding. In order to ensure optimisation of available funds, the NCR continues to implement cost containment measures.

`��"��;��<��"�� ^��"�� "��:�;�� /��the three (3) year period. In addition, the NCR’s assets and management strategy is provided, as well as the capital expenditure projections.


Improved conditions of consumers, artists and opening up of markets for new patents players.

Facilitate broad-based economic participation through targeted interventions to achieve more inclusive growth.

• To protect consumers from abuse and unfair practices in the consumer credit market and address over-indebtedness.•� �̀�� registration of persons and entities.

• Decreased levels of reckless lending and unfair practices.•�U��"�� registration of persons and entities.

Strengthen capacity to deliver on the dti mandate.

Create a fair regulatory environment that enables investment, trade and enterprise development in an equitable and social responsible manner.

Promote a professional, ethical, dynamic, competitive and customer-focused working environment that ensures effective ��"��delivery.

• To monitor and improve NCR’s operational effectiveness.

•�� delivery.


(i) Projections of revenue, expenditure, borrowings and capex

`��;��+��"�� //��Y�Z|��<��"��%G'��"

OPERATIONAL EXPENDITURE YEAR 2018-2019 YEAR 2019-2020 YEAR 2020-2021

Personnel costs �?^$#G^�[[ ��^�?G^�$[ JG^��$^[8G

Administration costs 19,391,747 19,736,271 �[^G��^G8J

>��\>��//�� 27,964,764 ��^�[G^�[� 29,505,440

Total operational expenditure 131,969,711 137,383,838 143,119,852

CAPITAL EXPENDITURE YEAR 2018-2019 YEAR 2019-2020 YEAR 2020-2021

Fixed assets 3,626,014 3,734,795 G^�?$^�G�

ICT operational system 2,015,343 �^[8$^J�� 2,064,000

Total capital expenditure 5,641,357 5,791,783 5,910,838

TOTAL EXPENDITURE 137,611,068 143,175,621 149,030,690

INCOME YEAR 2018-2019 YEAR 2019-2020 YEAR 2020-2021

Fees from registrants ?#^8��^�?G ?�^?$?^��# 43,461,575

Transfers from the dti 75,361,000 �J^8�[^[[[ �G^J8�^[[[

Interest 1,000,000 1,000,000 1,000,000

Other income 19,677,225 20,130,750 20,612,115

TOTAL INCOME 137,611,068 143,175,621 149,030,690

YEAR 2018-2019 YEAR 2019-2020 YEAR 2020-2021

�� /�� 236,900 244,007 251,327

Computer Equipment 659,200 $��^J�$ 699,345

Furniture �[[^�8[ �[$^��$ �#G^[��

Q��;��\�� 2,529,064 2,604,936 �^$�G^[�?

ICT operating system 2,015,343 �^[8$^J�� 2,064,000

Total 5,641,357 5,791,783 5,910,838

The NCR’s projected capital expenditure programme for the next three years focuses on the continuous improvements on ICT infrastructure and implementation of the ICT disaster recovery plan. The capex programme is outlined below:


��

(ii) Asset and Liability Management

In terms of section 51(1)(c) of the PFMA, the Accounting Authority is responsible for the management,including the safeguarding, of assets and the management of revenue, expenditure and liabilities of the public entity. Within the NCR, the Asset Management Policy provides for the acquisition of assets when the need arises. Procurement processes are in line with legislative requirements as well as the NCR’s supply chain management policy. In addition, assets are effectively maintained and when required, disposed of in line with the requirements of the PFMA.


�� YEAR 2018-2019 YEAR 2019-2020 YEAR 2020-2021

Cash receipts from applicants and registered entities $#��8[�[$� 62 595 621 64 073 690

Cash paid to suppliers (47 356 511) %?��8GJ�J��' %?J��GG��JJ'

Cash paid to employees %�?�$#G��[[' %��?G��$[' %JG��$�[8G'

��activities

YEAR 2018-2019 YEAR 2019-2020 YEAR 2020-2021

*""��"�� (3 626 014) (3 734 795) %�G��?$��G�'

Development of ICT operational system (2 015 343) %��[8$�J��' ( 2 064 000)

Y�� :�;��/��actvities (5 641 357) %8��J#��G' %8�J#[��G�'

Cash absorbed by operations before transfers received

(70 719 643) %�?��#�' (79 046 162)

Transfer received 75 361 000 �J�8�[�[[[ �G�J8��[[[

Cash absorbed by operations 4 641 357 ?��J#��G� ?�J#[��G��

Finance Income 1 000 000 1 000 000 1 000 000

�� activities

5 641 357 5 791 783 5 910 838

�� - - -

��activities

- - -

Net decrease/increase in cash and cash equivalents

- - -

(iv) Capital expenditure programmes

The NCR’s projected capital expenditure programme for the next three years focuses on the continuous improvements on ICT infrastructure and implementation of the ICT disaster recovery plan. The capex programme is outlined below:

(v) Dividend policies

The NCR is a schedule 3A public entity receiving a transfer payment from the dti. Hence the NCR does not declare dividends.

YEAR 2018-2019 YEAR 2019-2020 YEAR 2020-2021

�� /�� 236,900 244,007 251,327

Computer Equipment 659,200 $��^J�$ 699,345

Furniture �[[^�8[ �[$^��$ �#G^[��

Q��;��\�� 2,529,064 2,604,936 �^$�G^[�?

ICT operating system 2,015,343 �^[8$^J�� 2,064,000

Total 5,641,357 5,791,783 5,910,838


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PART C: Links to other plans1. Asset management plan

The NCR continues to effectively manage and safeguard its assets. The NCR has implemented an ��/��"��"��/��/�� "�� +��`��"��/��+��" ��L�� +��Obsolete and redundant assets are disposed of in line with the NCR Assets Management Policy and Treasury Regulations. The Facilities department is responsible for repairs and maintenance of the NCR assets. The NCR continues to ensure that its assets are adequately insured.

2. Information technology plan

The NCR makes extensive use of ICT systems to deliver on its mandate. It is also in the process of "�� ;� � ��/��"� U�`� ��/� �� ;�� "� �� elivery. The NCR has aligned its ICT Governance Framework to the Department of Public Service *"/��%�>Q*'��`�� [#�\#J��;��+�� /��/��U�`�infrastructure and the implementation of the ICT Disaster Recovery Plan.

3. Risk management and Fraud prevention plan

3.1 Fraud Prevention Plan: The NCR fraud prevention plan has been developed within the context of the Risk Management framework with the aim to reduce fraud to an absolute minimum and effect policies and procedures to maintain the risk of fraud within tolerable levels, and preferably zero, at all times. The Public Finance Management Act, Act No.1 of 1999 (PFMA), as amended, has as its prime objective, to secure transparency, accountability and management of revenue, assets, and liabilities within a spirit of good corporate governance, of the institutions to which the NCA applies.

The main objectives of the plan include: • To create an anti-fraud culture in which countering fraud is the joint responsibility of all stakeholders. • To ensure that the totality of anti-fraud measures represents the strongest deterrent possible to those perpetrating or considering perpetrating fraud. • To develop the most effective measures to prevent fraud by developing systems with administrative and technical features, which make the NCR less vulnerable to fraud. • To establish the most effective processes to detect fraud by ensuring that departments have the ability to detect existing and new types of fraud effectively and timeously and implementing effective liaison procedures to ensure that prompt action is taken to minimise losses to the NCR. • To take appropriate legal action and apply realistic sanctions where an investigation reveals fraud by ensuring that there is integration of risk management, ownership of the control environment, investigative and legal skills. • To use all possible means to seek redress in respect of money and assets lost to fraud, by ensuring that the recovery of defrauded money and assets forms an essential part of our overall strategy, in order to ensure that committing fraud does not pay.


The main principles of the plan are: • The NCR’s creating a fraud intolerant culture; • Fraud Prevention; • Fraud Detection; • Fraud Investigation; • Appropriate action (e.g. prosecution, disciplinary action, etc.) and • Appropriate recovery or the application of sanction.

The Code of Conduct contains the fundamental ethical principles, which staff members and those who render services to the NCR on a contract basis, must adhere to. The principles are categorised as: • Professionalism and integrity; • Obligations to stakeholders; and • Conduct in relation to others.

Basic internal controls to prevent and detect fraud and the training of employees in internal controls and their day-to-day duties are critical to the success of this plan.

The systems, policies and procedures of the NCR prescribe various controls, which, if effectively implemented, would limit the risk of fraud. These controls are categorised as: • Prevention controls: • Authorisation • Custody of assets • Detection controls • Physical Supervision • Management information • Segregation of duties • Physical and information security: • Physical security • Information security

The fraud detection and investigation process involves the following: • Internal audit • Ongoing risk assessment and management • Fraud detection • Reporting and monitoring • Fraud policy

Implementation and maintenance of the fraud prevention plan includes: • Creating awareness • Communication • Ongoing maintenance and review


The Accounting Authority is responsible for ensuring that a formal risk assessment is undertaken at least annually for the purpose of making its public statement on risk management.

The NCR recognises that the consistent and efficient application of disciplinary measures is an integral component of effective fraud prevention. The NCR will continue to pursue the following steps to expedite the consistent, efficient and speedy application of disciplinary measures: • Creating awareness amongst employees of forbidden conduct in terms of the disciplinary code and regular monitoring and review of application of discipline with the objective of improving weaknesses identified. • Where managers�� "��+��"\�� discipline, the NCR will consider firm action. • The management of the NCR will improve awareness and knowledge of the relevant systems, policies and procedures. In the pursuit hereof, the NCR will create awareness of existing and new policies and procedures to ensure that all employees are made aware of, and adequately trained in, the implementation of the policies and procedures relevant to their duties and responsibilities. • The line management must be held accountable for complying with, and implementing, the NCR’s systems, policies and procedures and for preventing fraud. This will continually be addressed by reviewing job description and performance appraisal processes and aligning this to the entity’s strategy. Where managers are �� "��+��"\��"��^��Y�Z�;�� consider firm action. • The Fraud Prevention Policy, central to the Plan, addresses the stance of the NCR, including the response mechanisms in place to report, investigate and resolve incidents of fraud impacting the NCR. A critical component of the policy addresses the practical execution phases and guidelines for decision-making at different stages of the investigation. • The role of the NCR’s Deputy Chief Executive Officer (DCEO) includes ongoing maintenance and review of the Plan, amongst other tasks. Ongoing maintenance includes: • Steering and taking responsibility for the Plan; • Reviewing and making appropriate amendments to the Code and Fraud Policy; • Considering fraud threats to the NCR and making recommendations to other appropriate committees or management; • Evaluating fraud reports; • Considering criminal activity threatening the NCR and making fraud prevention recommendations with regard to areas for examination; • Monitoring action taken to implement recommendations relating to incidents of fraud; • Amending the awareness programme as necessary, and implementing the changes; and • Ensuring that ongoing communication and implementation strategies are developed and implemented. • The Plan will be reviewed on an annual basis, with quarterly implementation and progress reviews.


All reports or allegations received by the DCEO are to be investigated on their merits, with a copy to the Internal Auditor.

In the event that there is merit in the allegations, these must be recorded and reported to the CEO and investigated, if the CEO is involved, the allegation must be referred to the Minister of Trade and Industry for a decision.

If the person involved is an EXCO member, the allegations must be reported to the Chairperson of the NCR Audit Committee who must decide on the course of action to be taken.

The above processes ensure that uninvolved parties are not negatively affected by malicious reports and that the intent to cause such damage is dealt with and disciplinary action taken where necessary.

3.2 Key Strategic Risks The NCR manages the key strategic risks it faces on a regular basis. The continuous review includes the update of both the strategic and operational risks on a periodic basis.

The following table provides a summary of the NCR’s key strategic risks, as well as the control improvement plan to mitigate the risks.

Risk Name Risk Control Residual Risk Action

Financial - Monthly variance reports to compare actual vs budget;- Budget mid-term reviews and re-allocation of funds;- Approval of budget by AA after recommondation from EXCO and Audit and Risk Management Committee; - Invoicing off all registrants a month before fees are due;- Submissions of additional funding requests to the dti;- Prepared and submitted budget ��"��- Quarterly update to the Portfolio Committee;- New registration thresholds for credit providers are place;- New registration fee increases are in place;- PDA interest utilisation policy;- Registration of new entrants is ongoing;��Z��"�;��"�;�� decals issued annually upon renewal and not once off;��/��/��"�

Critical - Continue to engage with the dti for additional funding;- Implementation of imposition of penalties for late renewals; - Finalisation of the proposed Bill to offset enforcement costs against ��- Proposal on penalty fees for registration.

Progress on action plans:- On going engagements with the dti regarding additional funding continue;��*;�� proposed Bill to offset enforcement ��- ICT Systems for the Implementation of penalties are being developed.



Financial - Monthly variance reports to compare actual vs budget;- Budget mid-term reviews and re-allocation of funds;- Approval of budget by EXCO & Audit and Risk Management Committee; - Invoicing off all registrants a month before fees are due;- Submissions of additional funding requests to the dti;- Prepared and submitted budget ��"��- Quarterly update to the Portfolio Committee;- New registration thresholds for credit providers are place;- New registration fee increases are in place;- PDA interest utilisation policy;- Registration of new entrants is ongoing;��Z��"�;��"�;�� decals issued annually upon renewal and not once off;��/��/��"�

Critical - Continue to engage with the dti for additional funding;- Implementation of imposition of penalties for late renewals; - Finalisation of the proposed Bill to offset enforcement costs against ��- Proposal on penalty fees for registration.

Progress on action plans:- On going engagements with the dti regarding additional funding continue;��*;�� proposed Bill to offset enforcement ��- ICT Systems for the Implementation of penalties are being developed.

Service delivery - Payment of invoices within 30 days;- Entered into MOU with Credit Ombud;- Regular consumer education campaigns;- Regular engagements with provincial consumer protection ��- Capacity building workshops;- Ongoing improvement on the IT infrastructure;- Ongoing compliance monitoring and enforcement action;- Ongoing training sessions for NCR employees;- External evaluation of the call centre;- Regular engagements with registrants’ associations;- Regular engagements with the Reserve Bank (SARB);��Q!Q��/�� that are lodged; - Regular engagements with the media;- Quarterly sessions with the Portfolio and Select Committees;- Procedure manual for invoice payments in place; - Regular engagements with the dti and other government departments.

Major Control improvement action plans- Improvement on ICT infrastructure.



- Alerts and reminders in the Complaints ICT systems Service Delivery Improvement Plan in place;- Centralised ICT services to one service provider; - Effective contract management;- More desk top compliance conducted; - Commencement of enforcement instituted by various departments;- Establishment of Service Provider panels;- Imbizos in all provinces;- Service Delivery Improvement Plan implemented;��Q!Q�� for registration; ��{ �L�� renewals.

- Automated service rating of the call centre agents; - Implementation of disaster recovery plan; - Enter into MOUs with Provincial �� /��>��- Implement case management system for investigations;- Enter into MOUs with Department of Education, Stats SA, SAPS and SAHRC.

Progress on action plans:- Ongoing improvement on ICT infrastructure;- Implementation of disaster recovery plan is underway;- Automatic service rating of the call centre agents will form part of the call centre system upgrade.

Information Technology

- Assessment of the new IT infrastructure and implementation to date;- Off-site storage of backups;- Internal auditors ensure assurance role; ��Y�Z��{U`\��UUU�� Implementation plan documented; - Network infrastructure improved. - Additional servers acquired e.g. SAP, Operational system; - Network monitoring tool has been acquired; ��Y�;��L��;��"�*�� - ICT Disaster Recovery Plan and Policy in place; - ICT Steering and Operational committees in place; - Alignment of ICT governance framework; - Business Continuity plan reviewed.- ICT expert as a member of ARMC appointed.

Major Control improvement action plans:- Implement the Business Continuity plan for all critical business applications; - To implement the ICT disaster recovery plan; - Recruitment of additional skills; - Implementation of ICT Governance Framework;��/��"��Q*>��/�� Service Provider.

Progress on action plans:- Implementation of disaster recovery plan is underway;- Implementation of ICT Governance Framework is in progress.

Human Resources

- HR policies in place; - Wellness programmes in place; - Social Committee established; ��//� established; - Work place forum established; - Some vacant positions have been ��"��"��- Implemented the PMS in the whole organisation;- Other HR policies reviewed and approved;- Coaching;- Access to Senior Management;- Provisions of tools of trade.

Q�� Control improvement action plans:- Engagements with the dti for additional funding to continue in order to employ more staff;- Finding other sources of income; ��Z��;�<�+��U"��;�Q��/�� more learners;- Training interventions;��Q��+��- Remuneration benchmarking.



Progress on action plans:- Engagements with the dti for additional funding continue;��Z��;�<�+��- Ongoing training interventions.

Business Continuity

- Risk assessment on security performed; ��/��^�� extinguishers; - Information security policy in place; - Insurance cover in place; ��"�Q��//��\� Disaster Recovery Team established; - CCTV surveillance, Electric fence, perimeter lighting, access control and alarm system are in place; - Security scanner in place; - Request for extension for current premises approved;- Fire drills are conducted; ��/��\�� signage in place (OHSA); - Approved Disaster Recovery Plan; - Encryption for new laptops; - First Aid Kits available; - NCR has a generator in place to power the whole of NCR; - Medical Aid is compulsory for all employees;- Ongoing data encryption for new laptops;��*��\��"��"�

Q�� Control improvement action plans:- Information and physical Security Policies to be reviewed ; - Training for health and safety ��//��\��Z�� Team; - Engagement with dti to address the funding challenges; - To implement the DRP; - Implement the Control improvement action plans for all critical business applications; - Software upgrades for all staff; ��!��"�� equipment;- DRS MOU to be signed with the dti;- Implement Server Monitoring and Alert system which will notify if the ��\�/�L^�� /�"��̂ �;��:��"��^�U�� detection, server power failure, temperature(overheating) etc.

Progress on action plans:- Ongoing training for health and ��//��\�� Recovery Team;- Implementation of the DRP & Business Continuity plan in progress;��/��"� security equipment;- Information and physical Security Policies to be reviewed; - Training for health and safety ��//��\��Z�� Team; - Engagement with dti to address the funding challenges; - To implement the DRP; - Implement the Security Policy reviewed by State security agency. NCR Security Committee to effect the recommendations of the review.


4. Any subsidiary of statutory body reporting to the entity

Not applicable: The NCR does not have subsidiaries.

5. Service Delivery Improvement Plan

`�� ;�� /�� /�� ;�� "��"� �� /��/��`�� Q�U>� ;�� "��"^� ��"� ��"� �/��/��"� �� "� �� $� /�� " �� [#�\#�� L��"��+��U�`�� "��" ��^��NCR was unable to deliver on the call centre targets. As a result, approval was sought from the dti to defer �/��/��Q�U>�%��'��*��"��;��+��"��"��[#�\#J��

Materiality Significance Framework

Section in terms of PFMA

Requirement��

Quantitative Qualitative

51(1)(g) An Accounting Authority for a public entity must promptly inform the National Treasury on any new entity, which that public entity intends to establish, or in the establishment of which it takes the initiative, and allow the National Treasury a reasonable time to submit its decision prior to formal establishment.

R1,612,701(2% of total assets at G#\[G\#�'

Any transaction of this nature that causes any interest (equity or loans) to be taken by the public entity in the company to be established requires approval from the executive authority irrespective of its /��

54(2) Before a public entity concludes any of the following transactions, the Accounting Authority for the public entity must promptly and in writing inform the relevant treasury of the transaction and submit relevant particulars of the transaction to its executive authority for approval of the transaction: a) Establishment or participation in the establishment of a company;��+'�>�� partnership, trust, unincorporated joint venture or similar arrangement; c) Acquisition or disposal of a ��"�� company; d) Acquisition or disposal of a �� e) Commencement or cessation ��+ �� activity; and��'�*�� nature or extent of its interest ��^� trust, unincorporated joint venture or similar arrangement.

R1,612,701(2% of total assets at G#\[G\#�'

Any transaction of this nature that causes any interest (equity or loans) to be taken by the public entity in the company to be established requires approval from the executive authority irrespective of its /��

Where ownership is control is affected*�� \"�� ""� �� Y�Z� �� \+ "�� "� \��*�� \"�� "�� Y�Z|�� + ��\mandate.

A business activity that falls outside of a public entity’s core business should be ��""��


Section in terms of PFMA

Requirement��

Quantitative Qualitative

55(2) The annual report and �� /�� "� �� subsection 55(2) must include particulars of : a) any material losses through criminal conduct and any irregular expenditure and fruitless and wasteful expenditure that occurred during the ��" b) any losses recovered or written off

R1,612,701 (2% of total assets at G#\[G\#�'

Annexure: Indicator Profile

Items (SO1) Guide

1. Indicator titleA report on the study of the impact of affordability assessment regulations on consumers.

��A study conducted on the affordability assessment regulations.

3. Purpose/importance • Understanding the impact of the regulations on consumers and credit providers; and • Improving the regulations

4. Source/collection of data Affordability assessment regulations

5. Method of calculationA report on the study of the impact of affordability ssessment regulations on consumers with recommendations

6. Data limitationsExpertise Unclear TOR

7. Type of indicator Output

8. Calculation type NA

9. New indicator New

10. Reporting cycle Annually

11. Desired performance Improved compliance with the Act

12. Indicator responsibility Manager: Credit Provider Compliance


Items (SO1) Guide

1. Indicator titleNumber of investigations/compliance monitoring/ audits/raids/complaints evaluations conducted to enforce regulations.

��Enforcement of the Act through investigations, compliance monitoring and complaints evaluations.

3. Purpose/importanceTo decrease the levels of non-compliance with provisions of the Act.

4. Source/collection of data

• Referrals from other government entities• Proactive sourcing of information• Complaints received• Anonymous tip-offs• Media reports•�� "��"��•�� < "�/��\��"��

5. Method of calculation

•�Y��/��/��Y�� /�� Tribunal (NCT) • Copies of compliance notices issued (signed compliance notices) •�U��• Investigations reports • Complaints evaluations• Tip-off anonymous report

6. Data limitations • Z�� ]��̂ ��+ "�� • Tribunal and Tribunal rules • Y�� ;�"


8. Calculation type Numbers

9. New indicator Continues with changes from the previous year

10. Reporting cycle Quarterly and annually

11. Desired performanceImproved compliance with the Act and consumer redress

12. Indicator responsibilityManagers: Investigations and Enforcement, Complaints and CP Compliance


Items (SO1) Guide

1. Indicator title

Enforcement action taken on a percentage (%) of investigations/compliance monitoring/audits/raids/complaints evaluations conducted, where necessary for the whole year.

��Taking enforcement action against alleged non-compliance with the Act.



• Investigation reports • Compliance monitoring reports • �� "��"�� •�� < "�/��\��"�� • Complaints evaluation reports


Total number of investigations/compliance monitoring/audits/raids/complaints evaluations conducted for the whole year (where contraventions of the Act were found)

Total number of investigations/compliance monitoring/audits/raids/evaluation conducted for the whole year = Total percentage (%) of enforcement action taken

6. Data limitations Budget, resources and capacity


8. Calculation type Percentages and numbers

9. New indicator Continues with changes from previous year





Items (SO1) Guide

1. Indicator titleA report on the impact study of the effect of total cost of credit and credit life insurance regulations on consumers.

��A study conducted on the effect of total cost of credit and credit life insurance regulations.

3. Purpose/importance

• Understanding the impact of the regulations on consumers and credit providers; and • Improving the regulations


5. Method of calculationA report on the impact study of the effect of total cost of credit and credit life insurance regulations on consumers with recommendations.







12. Indicator responsibility Manager: Statistics & Research


Items (SO2) Guide

1. Indicator title

Number of credit provider investigations/ compliance monitoring/audits/raids/complaints evaluations relating to reckless lending and/or collection of prescribed debt conducted to enforce regulations.

��To decrease the levels of non-compliance with provisions of the Act.

3. Purpose/importanceTo combat reckless credit granting and over-indebtedness.


• Referrals from other government entities • Proactive sourcing of information • Complaints received • Anonymous tip-offs • Media reports •�� "��"�� • �� < "�/��\��"��


• Y��/��/��Y�� Consumer Tribunal (NCT) • Copies of compliance notices issued (signed compliance notices) •�U�� • Investigations reports • Complaints evaluations • Tip-off anonymous report




9. New indicator Continues without change from previous year

10. Reporting cycle Quarterly and Annually





Items (SO2) Guide

1. Indicator title

Enforcement action taken on a percentage (%) of investigations/compliance monitoring/audits/raids/complaints evaluations relating to reckless lending and or collection of prescribed debt where necessary for the whole year.

�� Enforcement of regulations through investigations


• Taking enforcement action against alleged non-compliance with the Act. • To decrease the levels of non-compliance with provisions of the Act.


• Investigation reports • Compliance monitoring reports • Media reports • �� "��"�� •�� < "�/��\��"�� • Complaints evaluation reports


Total number of investigations/compliance monitoring/audits/raids/complains evaluationsconducted for the whole year (where contraventions of the Act were found)

Total number of investigations/compliance monitoring/audits/raids/evaluation conducted for the whole year = Total percentage (%) of enforcement action taken

6. Data limitations •�Z�� ]��̂ ��+ "�� • Tribunal and Tribunal rules •�Y�� ;�"







Items (SO2) Guide

1. Indicator title

Number of multimedia awareness campaigns (radio/TV interviews/news print/community outreach programmes/social media) conducted on deceptive and unfair practices and consumer rights.

��Improving education awareness on the deceptive and unfair credit practices and consumer rights.

3. Purpose/importanceTo educate and create public awareness for consumers on deceptive and unfair credit practices and consumer rights through multimedia awareness campaigns.


• Complaints received; • Investigations conducted; • Statistics; •�� • Media; • Stakeholder engagements.


• Media briefs; • News Clippings; • Interviews clips; • ��]�{��"�� • Campaign reports; •��/��;��" ��"�

6. Data limitations Training, capacity and funding





11. Desired performanceTo increase the level of public awareness on deceptive and unfair credit practices

12. Indicator responsibility Manager: Education & Communications



Items (SO3) Guide

1. Indicator titleNumber of credit bureaus monitored and disputes evaluated.

�� To monitor compliance by credit bureaus.

3. Purpose/importanceIncrease compliance by credit bureaus in respect of their obligations in terms of the NCA.


• Form 43 annual reports • Credit bureau audited reports • Compliance monitoring plan • Media reports • Complaints evaluation reports


• �� "��L�� •�U�� • Compliance requirements letter sent to credit bureaus requesting information; •�* "��/��/��"��+ �� • Proof of compliance from credit bureaus;

6. Data limitations

• Industry readiness • System developments either by credit bureaus or industry. •�Z�� ]��̂ ��+ "��



9. New indicator Continues with changes from previous year.



12. Indicator responsibility Manager: Credit Bureau Compliance

Items (SO3) Guide

1. Indicator titleEnforcement action taken on a percentage (%) of monitored credit bureaus where necessary.

��Taking enforcement action on non-compliant credit bureaus.



• Form 43 annual reports; • Proactive sourcing of information; • Complaints received; • Anonymous tip-offs; • Media reports.


Total number of monitored non-compliant credit bureaus

Total number of monitored credit bureaus = Total percentage (%) of non-compliant credit bureaus

6. Data limitations










Items (SO3) Guide

1. Indicator titleNumber of audited reports submitted by registered credit bureaus and enforcement action taken where necessary.




• Form 43 annual reports • Credit bureau audited reports • Compliance monitoring plan


• �� "��L�� • U�� • Compliance requirements letter sent to credit bureaus requesting information; • Audit confirmation reports from credit bureaus.

6. Data limitations

• Industry readiness • System developments either by credit bureaus or industry. • Z�� ]��̂ ��+ "��



9. New indicator Continues without change from previous year.





Items (SO3) Guide

1. Indicator title% of received credit bureau audited reports for ��!"�#��$��&��action taken where necessary.

��The indicator seeks to highlight non compliances �"��"�+�� "��"��+ ��


4. Source/collection of data • Credit bureau audited reports • Form 43 annual reports


• Received credit bureaus audited reports; • Received completed Form 43 returns from credit bureaus; • Referral memos to investigations department; • Compliance notices issued; • Annual compliance review reports; • Approved internal memos.

6. Data limitations Z�� ]��̂ ��+ "��








Items (SO4) Guide

1. Indicator title% of uptime availability of the legacy ICT (Registrations and Complaints) systems.

��The indicator seeks to highlight the system availability ��/��

3. Purpose/importance�̀��/��"��"��

To assess the down time and uptime availability of the system

4. Source/collection of data Report from the systems.

5. Method of calculationICT network monitoring report (Registrations and Complaints ICT system)

6. Data limitations

• Non commitment of service provider, stakeholders ��"\�� • Out-dated ICT hardware. • Capacity


8. Calculation type Percentage


10. Reporting cycle Quarterly reports

11. Desired performance �̀�� "��"��

12. Indicator responsibility ��


Items (SO4) Guide

1. Indicator title Approved service delivery improvement plan

��`��"��L��/��of the NCR

3. Purpose/importance To improve service delivery

4. Source/collection of data • Report from the systems • Performance information reports

5. Method of calculation Signed SDIP document

6. Data limitations

• Capacity • Expertise & budget • Resources (ICT systems) • Cooperation from the SDIP task team






12. Indicator responsibility Manager: Complaints department


Items (SO5) Guide

1. Indicator title

% of new applications registered in the consumer credit market within 10 business days of receipt of signed proposed conditions and payment of registration fees.

��`��"��L��/��registration process of persons and entities.

3. Purpose/importance �̀��/��

4. Source/collection of data • Registration fees collected; • Signed proposed conditions of registration received.


Total number of applications registered within 10 business days

Total number of applications registered= Total percentage (%) of new applications registered

6. Data limitations Training, capacity and ICT systems



9. New indicator Continues without change from the previous year.


11. Desired performanceIncreased number of registered persons and entities leading to job creation and establishment of SMMEs.

12. Indicator responsibility Manager: Registrations


Five YearStrategic Plan2018/19 - 2022/23

AA - Accounting Authority

ARMC - Audit and Risk Management Committee

ADR - Alternative Dispute Resolution

CB - Credit Bureau

CCI - Consumer Credit Index

CCMR - Consumer Credit Market Report

��

��

COTII - Council of Trade and Industry Institutions

��

CP - Credit Provider

��

dti - Department of Trade & Industry

DPSA - Department of Public Service Administration

EXCO - Executive Committee

FSRA - Financial Sector Regulation Act

ICT - Information Communication Technology

MICTSETA - Media Information and Communication Technologies Sector Education and Training Authority

NCA - National Credit Act

NCAA - National Credit Amendment Act

NCR - National Credit Regulator

NCT - National Consumer Tribunal

PDA - Payment Distribution Agents

PFMA - Public Finance Management Act

SADC - Southern African Development Community

SDIP - Service Delivery Improvement Plan

SMME - Small Medium and Micro Enterprises

WRSETA - Wholesale and Retail Sector Education and Training Authority

Effective - Successful in producing a desired or intended result

Enhance - Improve the quality of performance

Support - To give assistance

Facilitate - To make an action or process easier

Abbreviations

Definitions used to measure performance

68 | National Credit Regulator - 5 Year Strategic Plan 2018/19 -2022/23

Foreword by the Minister................................................................................................................. 71

Overview by the Accounting Authority ........................................................................................... 73

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PART A: Strategic Overview ........................................................................................................... 79

1. Vision .......................................................................................................................................... 79

2. Mission ........................................................................................................................................ 79

3. Values .......................................................................................................................................... 79

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Table of Contents

National Credit Regulator - 5 Year Strategic Plan 2018/19 - 2022/23 | 69

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10.4 Capital expenditure programmes ............................................................................... 91

10.5 Dividend policies ........................................................................................................ 91

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11. Asset management plan (narrative) .......................................................................................... 92

12. Information technology plan (narrative) ................................................................................... 92

13. Risk management and Fraud prevention plan ......................................................................... 92

13.1 Fraud Prevention Plan: ............................................................................................... 92

13.2 Key Strategic risk ........................................................................................................ 95

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3. Foreword by the MinisterW�� +��"� �^� ��"�after the National Credit Regulator’s (NCR’s) tenth year anniversary, we are reminded once more about our purpose to continue to strengthen consumer protection in the consumer credit industry while facilitating the sustainability and continued development of the credit industry.

U�� _�� [#�^� `�� z��"� {��L|�� Global Economic Prospects report provided an outlook for potential growth in each of the six global regions. “In Sub-Saharan Africa: Growth in the region is anticipated to pick up to 3.1 percent in 2018 from 2.4 percent in 2017. South Africa is forecast to pick up to 1.1 percent growth in 2018 from 0.8 percent in 2017.” (Source: The World Bank: Press Release dated 9 January 2018: Global Economy to Edge up to 3.1 percent in 2018 but Future Potential Growth a Concern).

The South African forecast is also supported by data released by Statistics South Africa. The economy of South Africa was reported to be on a recovery path. The economic activity in Q3 rose to 2.0% quarter-on-quarter- (Source: Focus Economics, December 8, 2017).

This showed that the economy was gaining traction post the recession in Q2. Unemployment in South Africa still remains a challenge though.The unemployment rate was recorded at 27.7 ��^��"��"��"�� 2017 - the highest rate in 13 years, according to Trading Economics.

In terms of the TransUnion Consumer Credit Index (CCI), consumer credit health improved (albeit marginally), even though there was a slight decline in Q3 in 2017 at 53.9%, from Q2 in 2017 at 54.1% (an index level of 50 is considered the �+��L��|� ��^� ;�� ;�� :��worsening credit health).

The results of the index were reported during a dire period of challenging economic conditions ��"��;��>��;��Q� ��*��]�(Source: Southern Consumer Credit Health “No room for complacency”, 20.11.2017).

A similar trend was reported in the Credit Bureau Monitor published by the NCR. The report is based on consumer credit data held by registered Credit Bureaus.

Consumers considered to be impaired were J��/�� GJ�G$�� 8�[�� /�� "��active consumers as at end September 2017 (Q3). This was an increase from Q2 at 9.69million or 39.1%.



Year-on-year since September 2015, however, there was an improvement in the percent of impaired consumers - 2015: 42.3%; 2016: 40.6%; 2017: 39.36%.

A consumer is classified as impaired if at least one account is three or more months in arrears, or has adverse listings, or has a judgement or administration order. The sluggish economic growth, high unemployment, consumer over-in-debtedness and uncertainty in a volatile global economy all place consumers under intense pressure and risk.

The National Credit Act No 34 of 2005 (the Act) as amended is a Government legislation enacted to amongst others, promote and advance the social and economic welfare of South Africans, promote a fair, transparent, responsible and accessible credit market and industry and to provide for consumer protection.

The Act established the National Credit Regulator (the NCR) which commenced operations in 2006. In order to deliver on the above legislative mandate, the NCR developed five (5) Key Strategic Objectives for the period �[#�\#J�]��[�[\�#�

The NCR objectives are aligned to the Key Policy Areas of the Department of Trade and Industry, the National Development Plan, theMedium Term Strategic Framework and the Nine Point Plan and require the NCR to; Promote responsible credit granting, Protect consumers from abuse and unfair practices and address over-indebtedness; Enhance the quality and accuracy of consumer credit information; improve NCR’s operational effectiveness; and Facilitate efficient registration of persons and entities to include those involved in consumer credit operating underground to be formalised.

Government has considered it necessary to develop a statutory mechanism to assist low income over-indebted consumers who falter;through debt counselling and the personal insolvency regime.

Therefore, in addition to the above work, the NCR will continue to participate in discussions relating to the Debt Intervention Bill introduced by the Portfolio Committee on Trade and Industry.

It is anticipated that the NCR will be one of the implementing agencies for debt intervention so that more over-indebted consumers are rehabilitated and given an opportunity once more to participate in the consumer credit industry and mainstream economy.

In spite of the challenges that the NCR may continue to face in the future, I am confident that the NCR will possess the resolve and resilience to overcome these challenges and will, therefore, deliver on its mandate.

I am pleased to release its 3-year Annual >��/�� >�� [#�\#J� �� [�[\�#� ��"�� 8�� Q�� >�� [#�\�[#J� ��[��\�G� ;�� "�� ;� �+<�� ;�� +�met with the continued support of the dti.



4. Overview by the Accounting Authority

The past year marked the tenth anniversary of the National Credit Regulator (NCR) which coincided with the events that started the global financial crisis and the world has changed significantly since then.

This calls for the need for cooperation with other key stakeholders, including regulators, locally and internationally and acting more proactively and effectively, to identify and address market problems. Consumer expectations have changed and they have become more empowered. We now live in an era where technology and social media are at our fingertips. Regulatory technology has to be developed and leveraged to enhance the NCR’s reach, impact, and effectiveness. Every consumer now has unprecedented access to information and it is, therefore, necessary for business and regulators to step up and respond accordingly.

The NCR is committed to continuing to build a consumer credit market that works for consumers, the credit industry and for the South African economy. A desire for fair access to legitimate credit, an alternative to abusive credit practices, and high quality service must remain the hallmark of the credit industry.

As a regulator, it is important to use our mandate to act more efficiently to identify andaddress market problems. We need to ensure that consumers receive fair, transparent and responsible access to credit while educating consumers to make sound financial decisions for themselves. The current economic climate in South Africa is slowly improving, which means that consumers will be in better shape to weather economic storms. There are promising signs that the consumer credit market is poised to perform well in 2018. The economy grew by 2.0% in the three months to September 2017.

This is in line with growth in Sub-Saharan Africa which is estimated to have rebounded to 2.4% in 2017 from 1.3% in 2016. The projections are that regional growth will rise to an average �� G�$�� [#J\�[� �� (article on Sub-Saharan Africa, by Gerard Kambou – Global Economic Prospects, January 2018).

High unemployment, however, remains a major social challenge and if this is not addressed, it will result in decreased household consumption. The priorities of the NCR are aligned with the Key Policy Areas of the Department of Trade and U�" �� %"��'� �� [#�\#J� �� ̂ � ��National Development Plan, the Nine Point Plan and the Medium Term Strategic Framework.



These focus areas reflect the NCR’s vision of promoting a South African consumer credit market which is fair, transparent, accessible and contributing to South Africa’s socio-economic development. The NCR operates under the ambit of the National Credit Act No 34 of 2005 (the Act) as amended. A high level situational analysis conducted identified trends in the developments that are likely to influence the consumer credit industry and impact the NCR over a period of time. The factors impacting on the regulatory environment include the following:

!�� (�� ) According to the NCR Consumer Credit Market Report and Credit Bureau Monitor which cover credit market information up to September 2017, ��"�� + �� "� ��"�� 8�[�� /��credit-active consumers for the quarter ended September 2017, an increase of 0.32% when compared to the 24.25 million in the quarter ended September 2016.

The number of consumers classified in good standing increased by 115,000 to 15.21 million. The percentage number of consumers classified in “good standing” accounted for 60.64% of the total credit-active consumers. This was an increase of 1.26% year-on-year. One of the most significant trends observed in terms of credit granted for the quarter ended September 2017 is that the total outstanding consumer credit balances (or gross debtors’ book) was R1.73 trillion, representing a year-on-year growth of 3.44%.

The above consumer credit insights will help us guide our strategy and planning going forward. They indicate that although consumercredit health is improving, consumers remain credit stretched. These trends are supported by the Consumer Credit Index (CCI) published by TransUnion. The index “measures” the aggregate consumer loan repayment record, tracks the use of revolving consumer credit facilities as an indicator of distressed borrowing, estimates household cash flow and quantifies the relative cost of servicing outstanding debt.

These aspects are then combined into a single indicator of credit health” (TransUnion Q3 2017 Consumer Credit Index Report). The CCI dropped slightly to 53.9 in Q3 from 54.1 in Q2, but because it remained above 50.0 (where 50.0 is the breakeven point), this is an indication of some improvement in consumer credit health.

In an article titled “Bad Debts better than a year ago, but the picture for this year is mixed” by Tammy Foyn, dated 17 August 2017, it is reported that bad debts for South Africans improved compared to the previous year and that indebtedness of households has been easing. Household debt to disposable income ratio as ��"� �� +� �� [�� [#G� ��"� �� ;��reduced to 75% for Q2, 2016 and further reduced to 74% for Q3 of 2017.

`�� [[�� ""� �� /� �� %Q� ��@� { �� ]� �`�� biggest risks every South African household faces in 2017”, January 2017) enforcing federal consumer financial laws and protecting consumers in the financial marketplace.

Despite improved consumer credit health, consumers are still not out of the woods. Measures will have to be identified to continue to improve consumer credit health by preventing financial harm to consumers while promoting responsible and sustainable lending practices that benefit them.

*��(��)�The Credit Industry Forum continues to provide a neutral platform to discuss cooperation between various industry associations to find solutions to industry challenges in the credit industry. The NCR will also continue to engage on a regular basis with other local and international regulators such as the South African Reserve Bank, Financial Services Board, the Competition Commission, and the Consumer Financial Protection Bureau in the United States. The main function of the Bureau is to enforce federal consumer financial laws and protect consumers in the financial marketplace.


NCR, therefore, collaborates with other regulators to share guiding principles and best practices. In terms of the National Credit Act, as amended, and the Financial Sector Regulation Act, 9 of 2017 (FSRA), which will implement the Twin Peaks model for financial regulation and supervision, the NCR will cooperate with regulators to be established under the FSRA.

The NCR participates in quarterly regulatory cluster meetings of the Council of Trade and Industry Institutions (COTII) which facilitate sharing of information and pulling resources to work together as regulators. The regulators who form COTII all report to the dti.

Collaboration regulation is about having a holistic view of the regulatory environment and an inclusive dialogue across sectors. It is important for sharing of information, experiences in terms of best practices in different regulatory aspects.

��$��)�The NCR working jointly with local Tribal Authorities in rural areas of most provinces, will conduct community outreach programmes (“Imbizos”) aimed mainly at pensioners to create awareness relating to their rights and responsibilities as consumers in the credit industry.

The NCR will continue to focus on visits to rural areas as most consumers in the credit market who reside in these areas form part of the vulnerable communities that must continue to be protected from financial harm. NCR will empower consumers in general by assisting them to understand the costs and risks of financial decisions, build trusted relationships that are informative so that they can make better informed choices and live better financial lives.

$��) This ensures compliance with the Act and enforcement of the Act to hold violators accountable by utilising a range of compliance monitoring and enforcement tools. A full update on matters before the National Consumer Tribunal and the courts are in the section on “Recent Court Rulings’’.

The enforcement of the Act is one of the key functions of the NCR. This is primarily done through conducting investigations. These investigations are informed by complaints from consumers, trends identified in the media, referrals from other institutions and compliance monitoring.

�� #�� ) As a result of the prudent financial management and corporate governance practiced, the NCR has always obtained an unqualified audit opinion and aims to achieve a clean audit opinion going forward. To this end the NCR holds regular engagements with Assurance Providers (Internal and External Auditors) through combined assurance forums. It is also important for the NCR to effectively and efficiently deliver on its mandate.

A service delivery improvement plan is being developed and will be implemented from �� [#�\#J� �� z� �� financial challenges encountered in executing the planned strategic activities. To achieve the long-term goals, we will need to ensure that the strategic plan is robust. Management will need to be flexible and alert to new opportunities as they present themselves.

The NCR has continuously been focusing on measures to cut operational costs and simultaneously identifying other revenue streams to deal with funding challenges. For example, some of the work that was outsourced has been internalised by providing extensive training to staff. Some of the NCR legal advisors have been empowered to refer and defend matters at the Tribunal.

Measures that have been identified to supplement income include the following: to submit a proposal to the dti to increase registration fees; the PDA interest utilisation policy has been reviewed and a proposal has been submitted to the dti to utilise the PDA interest earned for additional purposes that will in the long run benefit consumers e.g. research and impact studies.


The NCR is committed to good governance practices. It complies with the prescripts of the Public Finance Management Act (PFMA) and Treasury Regulations.

The responsibilities of the Accounting Authority vest in the Chief Executive Officer. An Audit and Risk Management Committee (ARMC) is constituted in terms of the PFMA and Treasury Regulations. The Internal Audit function, which reports to the ARMC, is outsourced. The organisation has been working smartly to achieve most of the objectives it set out to meet. By the end of September 2017 (second � �� [#�\#�� '^� #[[�� the planned quarterly milestones had either been achieved or exceeded for the two quarters. This needs to be maintained going forward.

*�� [#�\#J�;�� "��following: Education and awareness campaigns on deceptive and unfair practices, and consumer rights; Monitoring and enforcement programmes in particular in relation to the new registrants.

The National Credit Amendment Act and its Regulations make provision for all credit providers to be registered with the NCR and the threshold has been reduced to R1,00; Monitoring and enforcement programmes in relation to collection and sale of prescribed debts and credit providers to be encouraged to refrain from doing this; Monitoring the implementation of the Affordability Assessment Regulations; Review of the cost of credit and credit life insurance; and improved publication on the work undertaken by the NCR and its success stories.

We have aligned the key performance areas with the strategic objectives and core themes of the dti. The vision and mission are articulated through strategic goals. Measurable performance indicators as well as an analysis of external and internal factors that could affect the ability to achieve our goals are indicated. Strategic risks, which we could be exposed to, as well as possible mitigating controls, are also identified.

The strategic thrusts driving the plan include: - To promote responsible credit granting, to protect consumers from abuse and unfair practices in the consumer credit market and address over indebtedness; to enhance the quality and accuracy of consumer credit information; to improve NCR’s operational effectiveness; and to facilitate efficient registration of persons and entities.

+��&��

A Debt Intervention Bill was introduced by the Portfolio Committee on Trade & Industry and published in November 2017 for public comment. The Bill seeks to bridge the gap between low income consumers who cannot afford to go under debt review, and those who do not have any income and assets.

There is currently no legislative mechanism to assist this category of consumers in the current legislative framework. It is anticipated that the NCR will be one of the implementing agencies of this Bill once enacted. Implementation of the {��/��//��[#�\#J��

NCR will need to be capacitated to be able to deliver effectively on this Bill. Deadline for submission of written comments by the public �� {�� ;�� #8� _�� [#�� `�� >��Committee has commenced with public hearings regarding the Bill.

I would like to thank the NCR Executive Team, Management and personnel for their efforts, energy and dedication in providing a valuable contribution in the development of the consumer credit market.

This has assisted the NCR to make strides in achieving its strategic goal of protecting consumers in the country. The continued dedication and passion displayed by the NCR employees will go a long way in making a difference in the lives of many vulnerable communities in South Africa.


My gratitude is also extended to the dti in advancing socio-economic development in the country. The NCR will strive to improve its efficiency and effectiveness in the implementation of the Act and protection of consumers.

I am grateful to the Honourable Members of the Portfolio Committee on Trade & Industry, the Honourable Members of the Select Committee on Trade and International Relations, the Honourable Minister of Trade and Industry, Dr Z�+� ��^� �� ^� !�� October, the Group Chief Operating Officer, Ms Jodi Scholtz, and the Acting Deputy Director-General, Mr MacDonald Netshitenzhe for their guidance and continued support of the NCR.

I would also like to extend my sincere appreciation to the Members of the Audit & Risk Management Committee, for their dedicated energies and time they devote to the NCR.



2. Official sign-off��

• Was developed by the management of the National Credit Regulator under the guidance of Mrs N Motshegare, who is the CEO and Accounting Authority.

• Was prepared in line with the current Strategic Plan of the National Credit Regulator.

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Part A: Strategic OverviewThis section describes the vision, mission, values, strategic goals and objectives of the National Credit Regulator (NCR). Furthermore, it provides an overview of the products and services, recent court rulings and ��/��L��"��/��L��: ��;��L��Y�Z�

1. Vision

The vision of the NCR is:

“To promote a South African consumer credit market that is fair, transparent, accessible and dynamic.”

2. Mission

The mission of the NCR is:

`�� "��/��"��/��Q� ��*��+�@�] • regulating for a fair and non-discriminatory market for access to consumer credit; and

• promoting responsible credit granting, use and effective redress.

3. Values

The values of the NCR are:

Service ExcellenceWe strive for service excellence that exceeds the expectations of all stakeholders.

IntegrityWe are committed to honesty and integrity without compromise.

EmpowermentWe strive for empowerment in the consumer credit market and we are also committed to employee empowerment.

Good Corporate GovernanceWe strive to be a model of good corporate governance at all times.

4. Legislative Mandate

The legislative mandate of the NCR is as follows:

• To promote a fair and non-discriminatory marketplace for access to consumer credit and for that purpose to provide for the general regulation of consumer credit improved standards for consumer information; • To prohibit certain unfair credit and credit market practices; • To promote responsible credit granting and use and for that purpose to prohibit reckless credit granting; • To provide for debt re-organisation in cases of over-indebtedness; • To regulate credit information; and • To promote a consistent enforcement framework relating to consumer credit.


5. Services

The NCR renders the following services, in accordance with the requirements of the NCA.

• Register credit providers, credit bureaux, PDAs, ADRs and debt counsellors, and monitor their compliance with the Act. • Educate and create awareness of the protection that the NCA offers; • Research the credit market and its trends, monitor access to credit and the cost of credit to identify factors that may undermine access to credit, competitiveness in the credit market and consumer protection; • Advise government on policy and legislation; • Receive and investigate complaints and ensure that consumer rights are protected; and • Enforce the NCA and take action against contravening entities.

6. Recent Court Rulings

The NCR appraises the rulings and decision of the High Courts and the National Consumer Tribunal on a regular basis. The likely impact of these decisions on the NCR’s functions and mandates is taken into account when we craft our strategic plans. A brief summary of recent court decisions and rulings is provided below:


Truworths and others vs NCR and dti

Western Cape High Court Case No: ?G�8\#$

This is a High Court review of the affordability regulations by the clothing retailers. The matter ;�� "� �� ^�� "� #[� * � �� [#�� "� ;� �;��judgement.

MFSA vs NCR and dti North Gauteng High Court Case No: #$�?$\#$

This is a High Court review of Regulation 42- limitation on fees and interest by MFSA in which the matter was ruled in favour of MFSA and the NCR and dti have launched an appeal which was heard on 12 and 13 December 2017 and we await judgement.

MFSA vs NCR, dti and NCT

North Gauteng High Court Case No: $?$?$\#$

This is an application for a Declaratory Order regarding the interpretation of section 102 that was brought by the MFSA. MFSA would like the court to interpret the section as permitting for the inclusion of initiation fees into the deferred amount for all types of credit agreements, and not just the credit agreements mentioned in section 102. The parties are still exchanging pleadings and as soon as the pleadings have closed the matter will be set down for a hearing.



Bridge Corporate (Pty) ��"��Y�Z

North Gauteng High Court Case No: ��$�\#?

`�� {��"�� %>��'� ��"� �� "� �� High Court for an order to declare sections 55 and 57 of the NCA, which grant the NCR powers to issue compliance notices, unconstitutional. The matter is � ��""� ��"�� "��{��"��%>��'��"�

Bayport vs Minister of Justice and NCR

North Gauteng High Court Case No:��$J\�[#?

Bayport brought an application to declare consent to foreign jurisdiction as legitimate, in spite of the express prohibition in Section 90(2)(k)(vi) (bb) of the NCA. We await a date of set down for the matter to be heard.

SAFPS vs NCR and NCT North Gauteng High Court. Case No: $$[\�[#$*

This is an appeal by SAFPS against the decision of the NCT that found SAFPS guilty of prohibited conduct and for breaching the NCA regarding retention periods of adverse listings for credit bureaus. On 30 November 2017 the North Gauteng High Court upheld the appeal by SAFPS. The NCR is appealing the High Court decision in the Supreme Court of Appeal.

NCR vs Finbond National Consumer�̀�+ ��Y�`\�$$�J\

�[#8\#?[%#'%>'

The NCR referred Finbond to the NCT for charging consumers unreasonable cost of credit life insurance. The matter was heard on the 25th July 2017 and the NCT dismissed the NCR’s case. The NCR is appealing the decision.

�;��Q��/��"��NCR and NCT

North Gauteng High �� @�*$J?\#$

`�� +��;�� "��Y�`� �� "�� ;�� +��"�conduct for the mis-selling of credit life insurance. `��/��"�;��!��[#��

NCR vs Shoprite Investments

National Consumer�̀�+ ��Y�`\G�J?$\

�[#8\#?[%#'

The NCR referred Shoprite to the NCT for allegations of reckless lending and mis-selling of credit life insurance. The matter was heard on the 20 June 2017 and the NCT ruled in favour of the NCR and found Shoprite � �� L�� "�� *� �� Z#� [[[� [[[� ;��imposed. Shoprite has appealed the decision and the NCR is opposing the appeal.

Getbucks (Proprietary) ��/��"��Y�Z��"�Another

North Gauteng High Court Case No: �[#88\#8

��+ �L�� %>��'� ��/��"� ��"� �� Court to declare Regulation 44 ultra vires and void and to seek declaratory relief regarding the process to be followed when NCR investigates complaints in terms of section 136(2). The parties are still exchanging pleadings and once the pleadings have closed, the matter will be set down for a hearing.



Moneyline Financial Q��%>��'��"��NCR

*??\#$ Moneyline has appealed the decision handed down by the NCT which ruled that the NCR acted lawfully and procedurally correct when investigating Moneyline. The merits of the matter relate to allegation of reckless lending towards the recipients of social security grantsby Moneyline. The matter was set down for a hearingon 6 December 2017 and it was postponed on accountof Moneyline not being ready to proceed. We now await a new date for the hearing.

NCR vs Diners Club SA and Std Bank

??��8\#$ This is an application by the NCR for an order declaring that the Diners Club agreement concluded with consumers, which is administered by Standard Bank on behalf of Diners Club SA, is a credit agreement as "��"� �� %?'�� *��`��/��;��+��"��#?�!��[#��

NCR vs Standard Bank North Gauteng High Court Case No: ???#8\#$

The NCR has brought an application for a declaratory order regarding the application of the common law principle of “set off” on credit agreements. Once all the pleadings have been exchanged between the parties, the matter will be set down for a hearing.

�"��"��"��NCR

North Gauteng High Court Case Case No: *�G�\�[#�

The NCR referred Edcon Group to the NCT for the unlawful charging of club fees to consumers, and the NCT ruled in the favour of the NCR. Edcon has launched an appeal against the decision of the NCT. The matter ;��+��"��#8�!��[#��

Y�Z��;��Q��%>��'��"

National Consumer�̀�+ ��Y�`\?#$�#\

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`�� Y�Z� ��"� �;�� Y�`� �� ; ��charging of club fees to consumers, and the NCT ruled �� ;��`��Y�Z�� "��against the decision of the NCT. The matter is set down ��#?�*��[#��

NCR vs Wesbank a division of First Rand {��L��/��"

National Consumer�̀�+ ��Y�`\��[[\

�[#�\#?[%#'

The NCR referred Wesbank a division of FirstRand {��L��/��"��Y�`��;��Wesbank’s debt collection practices, which revealed that Wesbank does not allow consumers to voluntarily surrender their motor vehicles, in contravention of Section 127.

NCR vs Standard Bank National Consumer�̀�+ ��Y�`\�J[?#\

�[#8\#?[%#'

The NCR referred Standard Bank to the NCT for reckless lending. The matter concerns the so called “699 Satinsky car scheme”. The NCT dismissed the application by the NCR and the NCR is appealing the decision.

NCR vs Nedbank National Consumer�̀�+ ��Y�`\G#$�[\

�[#8\#?[%#'

The NCR referred Nedbank to the NCT for reckless lending. The matter concerns the so called “699 Satinsky car scheme”. The hearing was set down for �J�_�� [#��U��"�"��;��"��"�;��postponed to a soon to be decided date.


7. Situational analysis

*��/��;�� "��L��"��/��"��/��"�� /�� L�� : �� /�� Y�Z�� ^� ��brief synopsis of the state of the credit market is provided. An analysis of the internal and external factors impacting on the NCR is then provided.

7.1 State of the Credit Market`�� "��"� �� ;��/��"��Q��/+��[#��/� ��"� ��Z?�G�8��+��/��"��Z?8��G#�+��/��"��[#$��`�� "��"+��|�+��L�increased by R57.44 billion (3.44%) for the quarter ended September 2017, when compared to the quarter ended September 2016. The value of the debtors book at the end of September 2017 was R1.73 trillion ��G��#��/��

For the quarter ended September 2017, the total rand value of new credit granted was R123.64 billion, with Mortgages comprising R37.54 billion (30.36%), Secured Credit R42.25 billion (34.17%), Unsecured Credit Z��J�+��%#��[G�'��"��"��Z#$�#G�+��%#G�[8�'�

Applications for registration of credit providers are steadily increasing. A total of 6 599 credit providers with 36 959 branches, 23 Credit Bureaus, 3 Payment Distribution Agents, 4 Alternative Dispute Resolution *��"�#�?�8�"+�� ;��"�;��Y�Z��G#�_�� [#��/��;��"��+��"��/��^��"��"�� whilst unregistered.

7.2 Performance Delivery Environment (external)

�� the work of the NCR: a) Certainty in the regulatory framework Uncertainty in the regulating enforcement can curb job creation. Regulatory certainty creates consistent application of the legislation resulting in desirable outcomes that have a positive impact � � � ��"��/��L��"�� /��/��"��"��+��`��Y�Z�� has worked closely with the dti to close the gaps that existed in the legislation through the National ��"��*/�"/��*��Y��#J��[#?��"�� @�*��"�+��*��/��^��"�� Insurance, Interest rates and fees; Requirements to register every person and entity that extends credit. Implementation of the regulations has commenced and will be closely monitored. Impact of these regulations will be conducted in the next 3 years.


BMW Financial Services %Q*'�%>��'��"��Y�Z

National Consumer�̀�+ ��Y�`\G#$�[\

�[#8\#?[%#'

A compliance notice was issued for the “on the road” fees. BMW has objected to the compliance notice by an application to the NCT. The NCR is opposing the ��"��"��;��"��{!z|��"��;��+��"��"��"��" �� ^�whereafter the matter will be set down for hearing.

Volkswagen Financial Q��%Q*'�%>��'��"��NCR

National Consumer�̀�+ ��Y�`\JG��J\

�[#�\8$%#'

A compliance notice was issued for the “on the road” fees. VW has objected to the compliance notice by application to the NCT. The NCR is opposing the ��"��;��"��


b) Increasing complexity and sophistication The evolution of the credit market has come with innovation by the industry. This continues to increase alternative consumer lending. The emergence of on-line, peer-to-peer lending and other new forms of lending in South Africa and other countries has brought new regulatory challenges for credit regulators. Close monitoring or scrutiny on compliance with the law will have to be done.

The NCR is also closely monitoring the introduction of the new credit products and the advertising methods of credit providers in order to curb the luring of consumers into debt traps. This in turn requires improved product knowledge and understanding by the NCR to be able to monitor their compliance with legislation effectively.

c) Stakeholder management The approach of the NCR towards stakeholder management is to facilitate open discussion and engagement with the industry and other stakeholders. Efforts are being made to achieve this objective while avoiding regulatory capture by the industry.

The NCR has established the Credit Industry Forum which serves as a platform for the NCR and industry to engage and reach agreement on industry issues. The forum represents all industry players and consumers. It plays an important role in resolving operational problems on the implementation of the legislation.

The forum continues to meet quarterly, several guidelines circulars have been issued to the industry emanating from these meetings. The NCR is a member of the African Consumer Protection Dialogue which is facilitated by the Federal Trade Commission of the United States (The African Dialogue). This forum brings together regulators from all over the African continent to discuss consumer protection issues and share information.

NCR will continue to participate in conferences arranged by the African Dialogue. The NCR also holds regular meetings with industry associations, registrants and magistrates. Ongoing meetings are also ��"�;��"��;�� "�� "�� the Reserve Bank of South Africa.

The NCR has also established networks with other regulators in the SADC region, United States of America and the United Kingdom. More relationships will be established with other regulators across the globe.

d) Challenges faced by the NCR The main challenge of the NCR is funding. The NCR requires additional funding to meet its operational requirements.

� � `�� Y�Z� �� "� �� ;�� /�� + "�� "�� +� �+�� legislative mandate.

7.3 Organisational Delivery Environment (internal)

��the NCR:

a) Processes, system and structure renewal A new human resource management system and a performance management system have been introduced.

b) Human Capital The NCR is focusing on staff issues and ensures that staff morale remains high. In order to increase ��Y�Z�� " ��/��*�"��"��;�Q��



Grow the manufacturingsector to promoteindustrial development,job creation, investment and exports.

Facilitate thetransformation ofthe economy topromote industrialdevelopment,investment,competitiveness andemployment creation.

• To promote responsible credit granting.• To enhance the quality and accuracy of consumer credit bureau information.

• Reduced levels of over-Indebtedness.• Affordable levels of credit promoted.• Improved quality and accuracy of consumer credit information.

c) Knowledge intensity In order to provide guidance to stakeholders and employees on the developments and trends in the credit market. This is achieved through measures such as issuing public notices, capacity building workshops, media statements, radio and TV interviews; community outreach programmes (Imbizos) and others. The NCR also publishes statistics on a quarterly basis on the level and nature of consumer indebtedness. In-house training sessions are provided for staff.

7.4 Description of the Planning Process

`��+��;�� //��;��/��the organisational strategic direction. The dti, Audit and Risk Management Committee and Internal audit play a pivotal role in that they make review and inputs to the process. Workshops are then held between executive members and the management team to develop the departmental operational objectives.

Management in turn engages with their respective team members to develop operational objectives which are in line with the business plan of the organisation. Upon approval of the strategic and operational objectives, all employees including executive management conclude performance contracts quarterly. 8. Strategic Alignment to the dti

`��"��^��Y�Z|��/��̂ �� /�� /�?�]��Employment through Inclusive Growth. In aligning its strategic priorities, the NCR took into account the external and internal environmental trends and issues as well as priorities of government which are the twelve (12) outcomes, NDP and the Nine Point Plan.

The alignment between the outcomes that the NCR seeks to achieve, the strategic objectives of the dti, its strategic outcome oriented goals, the NDP and the Nine Point Plan is set out below:

The Nine Point Plan includes “unlocking the potential of SMMEs, Cooperatives, townships and rural ��||�� ̀� �� "^� Y�Z� �� /�� "� �/�� +�� " ��turnaround times to register new entrants (persons & entities). This will result in increased job creation.

The dti strategic objectives and NCR outcomes



Improved conditions ofconsumers, artists andopening up of markets for new patents players.

Facilitate broadbasedeconomic participationthrough targetedinterventions to achieve more inclusive growth:

• To protect consumers from abuse and unfair practices in the consumer credit market and address overindebtedness.•� �̀�� registration of persons and entities.

• Decreased levels of reckless lending and unfair practices.•�U��"�� registration of persons and entities.

Strengthen capacity todeliver on the dtimandate.

Create a fair regulatoryenvironment thatenables investment,trade and enterprisedevelopment in an equitable and socialresponsible manner.

Promote a professional, ethical, dynamic,competitive andcustomer-focusedworking environment that ensures effective��"��delivery.

• To monitor and improve NCR’s operational effectiveness.

•�� delivery.


Part B: Strategic Objectives9. The strategic objectives the NCR pursues are as follows:

Programme 1 To promote responsible credit granting.

Programme statement The purpose of this programme is to reduce levels of consumer over-indebtedness by: (a) Understanding the impact of the regulations on consumers and credit providers; (b) Monitoring credit provider compliance with the regulations; (c) Enforcing compliance with the regulations; and (d) Improving the regulations.

Description of the programme Credit provider compliance monitoring and investigations will be conducted in order to assist credit providers to comply with affordability assessment regulations and the total cost of credit.

Baseline • * Credit provider compliance monitored in 9 provinces. Enforcement action taken on non-compliant credit provider where necessary. • * Fifty 50 investigations conducted and enforcement action taken where necessary. • * Service provider to conduct an impact study of the affordability assessment regulations on consumers procured.

Programme 2To protect consumers from abuse and unfair practices in the consumer credit market and address over-indebtedness.

Programme statement The purpose of this programme is to decrease the practice of reckless lending by credit providers. This will be implemented by conducting investigations and taking enforcement action on non-compliant credit providers and improving education awareness regarding deceptive andunfair practices and consumer rights.

Description of the programme Complaints reports that are lodged by consumers and reports of non-compliance reported by *�� "� � "�� ;�� +�investigated through reactive mechanisms. Appropriate enforcement action will be taken where necessary.

Baseline • * Seventy (70) credit provider investigations conducted and enforcement action taken where necessary. • 35 of any of the following: -Radio interviews -TV interviews -News print -Community outreach programmes on deceptive and unfair credit practices conducted.

��


Programme 3To enhance the quality and accuracy of consumer credit information.

Programme statement The purpose of this programme is to increase compliance by credit bureaus through compliance monitoring, complaints evaluation and investigations by taking appropriate enforcement action where necessary.

Description of the programme Compliance monitoring will be conducted by the NCR. Based on the outcome of the compliance monitoring, complaints evaluation and investigations, enforcement action will be taken where necessary.

Baseline •��%�'��"��+ �� /��"�� Enforcement action taken where necessary. • 100% of audited reports from credit bureaus reviewed and enforcement action taken where necessary.

Programme 4 To improve NCR’s operational effectiveness.

Programme statement The purpose of this programme is to improve the Y�Z|��"��"��

Description of the programme This will be done through continuous improvement of the ICT systems.

Baseline • *97% uptime of the ICT system. • Call Centre SDIP implemented for 6 months.

Programme 5'�� entities.

Programme statement The purpose of this programme is to increase theparticipation of SMMEs which would facilitate the creation of job opportunities.

Description of the programme Registering new entrants in the consumer credit market, i.e. Credit providers, Credit Bureaus, Payment Distribution Agents, Alternative Dispute Resolution and Debt Counsellors.

��

10. Financial Plan

��"�"��L�� Y�Z��z��/��"�� ^�and the need to regulate the credit industry and enforce the NCA, it is imperative for the NCR to optimise the available funding. In order to ensure optimisation of available funds, the NCR will continue implementing its cost containment measures, as well as ensuring 100% compliance with the National Treasury Instructions on cost containment.

`��"��;��<��"�� ^��"�� "��:�;�� /��%8'��"��U��""��^��Y�Z|��"�/��/��""^��;��capital expenditure projections.


10.2 Asset and liability management

10.3 Cash flow projections

In terms of section 51(1)(c) of the PFMA, the Accounting Authority is responsible for the management, including the safeguarding, of the assets and the management of the revenue, expenditure and liabilities of the public entity. Within the NCR, the Asset Management Policy provides for the acquisition of assets when the need arises. Procurement processes are in line with legislative requirements as well as the NCR’s supply chain management policy. In addition, assets are effectively maintained and when required, disposed of in line with the requirements of the PFMA.

`��;��+��"�� //��<��"��:�;�@

10.1 Projections of Revenue, Expenditure, Borrowings and Capex

`�� ;�� +�� "�� //�� Y�Z|�� <��"� �� period.

OPERATIONAL EXPENDITURE

YEAR 2018-2019

YEAR 2019-2020

YEAR 2020-2021

YEAR 2021-2022

YEAR 2022-2023

Personnel costs �?�$#G��[[ ��?G��$[ JG��$�[8G 97 950 356 #[��?��G

Administration costs 19 391 747 19 736 271 �[�G��G8J �[�JG��#[ 21 566 357

>��\>��//�� 27 964 764 ��[G��[� 29 505 440 30 390 603 31 302 321

Total operational expenditure 131 969 711 137 383 838 143 119 852 149 279 169 155 716 551

CAPITAL EXPENDITUREYEAR

2018-2019YEAR

2019-2020YEAR

2020-2021YEAR

2021-2022YEAR

2022-2023

*""��"�� 3 626 014 3 734 795 G��?$��G� 3 962 244 ?�[�#�###

ICT operational system 2 015 343 ��[8$�J�� 2 064 000 2 163 472 2 163 472

Total capital expenditure 5 641 357 5 791 783 5 910 838 6 125 716 6 244 583

INCOMEYEAR

2018-2019YEAR

2019-2020YEAR

2020-2021YEAR

2021-2022YEAR

2022-2023

Fees from registrants ?#�8��?G ?��?$?��# 43 461 575 43 895 542 44 506 112

Transfers from the dti 75 361 000 �J�8�[�[[[ �G�J8��[[[ 88 994 420 94 334 085

Interest 1 000 000 1 000 000 1 000 000 1 000 000 1 000 000

Other income 19 677 225 20 130 750 20 612 115 21 514 923 22 120 937

TOTAL INCOME 137 611 068 143 175 621 149 030 690 155 404 885 161 961 134

TOTAL EXPENDITURE: 137 611 068 143 175 621 149 030 690 155 404 885 161 961 134


�� activities

YEAR 2018-2019

YEAR 2019-2020

YEAR 2020-2021

YEAR 2021-2022

YEAR 2022-2023

Cash receipts from applicants and registered entities $#^�8[^[$� 62,595,621 64,073,690 65,410,464 66,627,049

Cash paid to suppliers (47,356,511) %?�^8GJ^J��' %?J^�GG^�JJ' %8#^G��^�#G' %8�^�$�^$��'

Cash paid to employees %�?^$#G^�[[' %��^�?G^�$[' %JG^��$^[8G' (97,950,356) %#[�^�?�^��G'

��activities

YEAR 2018-2019

YEAR 2019-2020

YEAR 2020-2021

YEAR 2021-2022

YEAR 2022-2023

*""��"�� (3,626,014) (3,734,795) %G^�?$^�G�' (3,962,243) %?^[�#^###'

New ICT System Development of ICT operational system (2,015,343) %�^[8$^J��' (2,064,000) (2,163,472) (2,163,472)

Y�� :�;��/��activities (5,641,357) %8^�J#^��G' %8^J#[^�G�' (6,125,715) %$^�??^8�G'

Cash absorbed by operations before transfers received (70,719,643) %�?^��^�#�' (79,046,162) %�G^�$�^�[8' %�J^[�J^8[�'

Transfers received 75,361,000 �J^8�[^[[[ �G^J8�^[[[ ��^JJ?^?�[ J?^GG?^[�8

Cash absorbed by operations 4,641,357 ?^�J#^��G ?^J#[^�G� 5,125,715 8^�??^8�G

Finance Income 1,000,000 1,000,000 1,000,000 1,000,000 1,000,000

Y��:�;��/��activities 5,641,357 5,791,783 5,910,838 6,125,715 6,244,583

��:�;��/�� - - - - -

Y��:�;��/��activities - - - - -

Y��"��\��"�cash equivalents - - - - -


YEAR 2018-2019

YEAR 2019-2020

YEAR 2020-2021

YEAR 2021-2022

YEAR 2022-2023

�� /�� 236,900 244,007 251,327 �8�^�$$ 266,634

Computer Equipment 659,200 $��^J�$ 699,345 720,326 741,935

Furniture �[[^�8[ �[$^��$ �#G^[�� 219,474 ��$^[8�

Q��;��\�� 2,529,064 2,604,936 �^$�G^[�? 2,763,577 �^�?$^?�?

ICT operating system 2,015,343 �^[8$^J�� 2,064,000 2,163,472 2,163,472

Total 5,641,357 5,791,783 5,910,838 6,125,715 6,244,583

10.4 Capital expenditure programmes

10.5 Dividend policies

The NCR’s projected capital expenditure programme for the next three years focuses on the ICT systems upgrade and implementation of the ICT disaster recovery plan.The capex programme is outlined below:

The NCR is a schedule 3A public entity receiving a transfer payment from the dti. Hence the NCR does not declare dividends.


PART C: Links to other plans11. Asset management plan

The NCR continues to effectively manage and safeguard its assets. The NCR has implemented electronic ��"��"��/��/��"�� +��`��"��/�� +�� " �� L�� +�� +�� "�redundant assets are disposed of in line with the NCR Assets Management Policy and Treasury Regulations. Facilities department is responsible for repairs and maintenance of the NCR assets. The NCR continues to ensure that its assets are adequately insured.

12. Information technology plan

The NCR makes extensive use of ICT systems to deliver on its mandate. It is also in the process of "�� ;� � ��/��"� U�`� ��/� �� ;�� "� �� delivery. The NCR has aligned its ICT Governance Framework to the Department of Public Service *"/��%�>Q*'��`�� [#�\#J�;��+�� /��/��U�`�� and implementation of the ICT Disaster Recovery Plan.

13. Risk management and Fraud prevention plan

13.1 Fraud Prevention Plan: The NCR fraud prevention plan has been developed within the context of the Risk Management framework with the aim to reduce fraud to an absolute minimum and effect policies and procedures to maintain the risk of fraud within tolerable levels, and preferably zero, at all times. The Public Finance Management Act, Act No.1 of 1999 (PFMA), as amended, has as its prime objective, to secure transparency, accountability and management of revenue, assets, and liabilities within a spirit of good corporate governance, of the institutions to which the NCA applies.

The main objectives of the plan include: • To create an anti-fraud culture in which countering fraud is the joint responsibility of all stakeholders. • To ensure that the totality of anti-fraud measures represents the strongest deterrent possible to those perpetrating or considering perpetrating fraud. • To develop the most effective measures to prevent fraud by developing systems with administrative and technical features, which make the NCR less vulnerable to fraud. • To establish the most effective processes to detect fraud by ensuring that departments have the ability to detect existing and new types of fraud effectively and timeously and implementing effective liaison procedures to ensure that prompt action is taken to minimise losses to the NCR. • To take appropriate legal action and apply realistic sanctions where an investigation reveals fraud by ensuring that there is integration of risk management, ownership of the control environment, investigative and legal skills. • To use all possible means to seek redress in respect of money and assets lost to fraud, by ensuring that the recovery of defrauded money and assets forms an essential part of our overall strategy, in order to ensure that committing fraud does not pay.


The main principles of the plan are: • The NCR’s creating a fraud intolerant culture; • Fraud Prevention; • Fraud Detection; • Fraud Investigation; • Appropriate action (e.g. prosecution, disciplinary action, etc.) and • Appropriate recovery or the application of sanction.

The Code of Conduct contains the fundamental ethical principles, which staff members and those who render services to the NCR on a contract basis, must adhere to. The principles are categorised as: • Professionalism and integrity; • Obligations to stakeholders; and • Conduct in relation to others.

Basic internal controls to prevent and detect fraud and the training of employees in internal controls and their day-to-day duties are critical to the success of this plan.

The systems, policies and procedures of the NCR prescribe various controls, which, if effectively implemented, would limit the risk of fraud. These controls are categorised as: • Prevention controls: • Authorisation • Custody of assets • Detection controls • Physical Supervision • Management information • Segregation of duties • Physical and information security: • Physical security • Information security

The fraud detection and investigation process involves the following: • Internal audit • Ongoing risk assessment and management • Fraud detection • Reporting and monitoring • Fraud policy

Implementation and maintenance of the fraud prevention plan includes: • Creating awareness • Communication • Ongoing maintenance and review


The Accounting Authority is responsible for ensuring that a formal risk assessment is undertaken at least annually for the purpose of making its public statement on risk management.

The NCR recognises that the consistent and efficient application of disciplinary measures is an integral component of effective fraud prevention. The NCR will continue to pursue the following steps to expedite the consistent, efficient and speedy application of disciplinary measures: • Creating awareness amongst employees of forbidden conduct in terms of the disciplinary code and regular monitoring and review of application of discipline with the objective of improving weaknesses identified. • Where managers�� "��+��"\�� discipline, the NCR will consider firm action. • The management of the NCR will improve awareness and knowledge of the relevant systems, policies and procedures. In the pursuit hereof, the NCR will create awareness of existing and new policies and procedures to ensure that all employees are made aware of, and adequately trained in, the implementation of the policies and procedures relevant to their duties and responsibilities. • The line management must be held accountable for complying with, and implementing, the NCR’s systems, policies and procedures and for preventing fraud. This will continually be addressed by reviewing job description and performance appraisal processes and aligning this to the entity’s strategy. Where managers are �� "��+��"\��"��^��Y�Z�;�� consider firm action. • The Fraud Prevention Policy, central to the Plan, addresses the stance of the NCR, including the response mechanisms in place to report, investigate and resolve incidents of fraud impacting the NCR. A critical component of the policy addresses the practical execution phases and guidelines for decision-making at different stages of the investigation. • The role of the NCR’s Deputy Chief Executive Officer (DCEO) includes the ongoing maintenance and review of the Plan, amongst other tasks. Ongoing maintenance includes: • Steering and taking responsibility for the Plan; • Reviewing and making appropriate amendments to the Code and Fraud Policy; • Considering fraud threats to the NCR and making recommendations to other appropriate committees or management; • Evaluating fraud reports; • Considering criminal activity threatening the NCR and making fraud prevention recommendations with regard to areas for examination; • Monitoring action taken to implement recommendations relating to incidents of fraud; • Amending the awareness programme as necessary, and implementing the changes; and • Ensuring that ongoing communication and implementation strategies are developed and implemented. • The Plan will be reviewed on an annual basis, with quarterly implementation and progress reviews.


All reports or allegations received by the DCEO are to be investigated on their merits, with a copy to the Internal Auditor.

In the event that there is merit in the allegations, these must be recorded and reported to the CEO and investigated, if the CEO is involved, the allegation must be referred to the Minister of Trade and Industry for a decision.

If the person involved is an EXCO member, the allegations must be reported to the Chairperson of the NCR Audit Committee who must decide on the course of action to be taken.

The above processes ensure that uninvolved parties are not negatively affected by malicious reports and that the intent to cause such damage is dealt with and disciplinary action taken where necessary.

13.2 Key Strategic Risks The NCR manages the key strategic risks it faces on a regular basis. The continuous review includes the update of both the strategic and operational risks on a periodic basis.

The following table provides a summary of the NCR’s key strategic risks, as well as the control improvement plan to mitigate the risks.



Financial - Monthly variance reports to compare actual vs budget;- Budget mid-term reviews and re-allocation of funds;- Approval of budget by EXCO & Audit and Risk Management Committee;- Invoicing of all registrants a month before fees are due;- Submissions of additional funding requests to the dti;- Prepared and submitted budget ��"��- Quarterly update to the Portfolio Committee;- New registration thresholds for credit providers are in place;- New registration fee increases are in place;- PDA interest utilisation policy;- Registration of new entrants is ongoing;��Z��"�;��"�;�� decals issued annually upon renewal and not once off;��/��/��"�

Critical Control improvement action plans:- Continue to engage with the dti for additional funding;- Implementation of imposition of penalties for late renewals;- Finalisation of the proposed Bill to offset enforcement costs against ��- Proposal on penalty fees for registration.

Progress on action plans:- On going engagements with the dti regarding additional funding continue;��*;��"� Bill to offset enforcement costs��- ICT Systems for the Implementation of penalties are being developed.

Service delivery - Payment of invoices within 30 days;- Entered into MOU with Credit Ombud;- Regular consumer education campaigns;- Regular engagements with provincial consumer protection ��- Capacity building workshops;- Ongoing improvement on the IT infrastructure;- Ongoing compliance monitoring and enforcement action;- Ongoing training sessions for NCR employees;- External evaluation of the call centre;- Regular engagements with registrants’ associations;- Regular engagements with the Reserve Bank (SARB);

Major Control improvement action plans:- Improvement on ICT infrastructure;- Automated service rating of the call centre agents;- Implementation of disaster recovery plan;- Enter into MOUs with Provincial �� /��>��- Implement case management system for investigations;- Enter into MOUs with Dept of Education, Stats SA, SAPS and SAHRC.



��Q!Q��/�� are lodged; - Regular engagements with the media;- Quarterly sessions with the Portfolio and Select Committees;- Procedure manual for invoice payments in place; - Regular engagements with the dti and other government departments;- Alerts and reminders in the Complaints ICT systems Service delivery improvement plan in place;- Centralised ICT services to one service provider; effective contract management;- More desk top compliance conducted;- Commencement of enforcement instituted by various departments;- Establishment of Service Provider panels;- Imbizos in all Provinces;- Service delivery improvement plan implemented;��Q!Q�� registration;��{ �L�� renewals.

Progress on action plans:- Ongoing improvement on ICT infrastructure;- Implementation of disaster recovery plan is underway;- Automatic service rating of the call centre agents will form part of the call centre system upgrade.

InformationTechnology

- Assessment of the new IT infrastructure and implementation to date;- Off-site storage of backups;- Internal auditors ensure assurance role;��Y�Z��{U`\��UUU�� Implementation plan documented;- Network infrastructure improved.- Additional servers acquired e.g. SAP, Operational system;- Network monitoring tool has been acquired;��Y�;��L��;��"�*�� - ICT Disaster Recovery Plan and Policy in place;- ICT Steering and Operational committees in place;- Alignment of ICT governance framework;- Business Continuity plan reviewed.- ICT expert as a member of ARMC appointed.

Major Control improvement action plans:- Implement the Business Continuity plan for all critical business applications;- To implement the ICT disaster recovery plan;- Recruitment of additional skills;- Implementation of ICT Governance Framework;��/��"��Q*>��/�� Service Provider.

Progress on action plans:- Implementation of disaster recovery plan is underway;- Implementation of ICT Governance Framework is in progress.



HumanResources

- HR policies in place;- wellness programmes in place;- Social Committee established;��//��+��"�- Work place forum established;- Some vacant positions have been ��"��"�- Implemented the PMS in the whole organisation;- Other HR policies reviewed and approved;- Coaching;- Access to Senior Management;- Provisions of tools of trade.

Q�� Control improvement action plans:- Engagements with the dti for additional funding to continue in order to employ more staff;- Finding other sources of income��Z��;�<�+��U"��;�Q��/�� more learners;- Training interventions;��Q��+��- Remuneration benchmarking.

Progress on action plans:- Engagements with the dti for additional funding continue;��Z��;�<�+��- Ongoing training interventions

BusinessContinuity

- Risk assessment on security performed;��/��^�� extinguishers;- Information security policy in place;- Insurance cover in place;��"�Q��//��\�� Disaster Recovery Team established;- CCTV surveillance, Electric fence, perimeter lighting, access control and alarm system are in place;- Security scanner in place;- Request for extension for current premises approved;- Fire drills are conducted;��"��/��\>�� signage in place (OHSA);- Approved Disaster Recovery Plan;- encryption for new laptops;- First Aid Kits available;- NCR has a generator in place topower the whole of NCR;- Medical Aid is compulsory for all employees;- Ongoing data encryption for new laptops;��*��\��"��"�

Q�� - Software upgrades for all staff;��!��"�� equipment;- DRS - MOU to be signed with the dti;- Implement Server Monitoring and Alert system which will notify if the ��\�/�L^�� /�"��̂ �;��:��"��^�U�� detection, server power failure, temperature(overheating) etc.

Progress on action plans:- Ongoing training for health and ��//��\�� Recovery Team;- Implementation of the DRP & Business Continuity plan in progress;��/��"�� security equipment;- Information and physical Security Policy reviewed by State security agency. NCR Security Committee to effect the recommendations of the review.


Items (SO1) Guide

1. Indicator titleA report on the study of the impact of affordabilityassessment regulations on consumers.

��A study conducted on the affordability assessmentregulations.

3. Purpose/importance • Understanding the impact of the regulations on consumers and credit providers; and • Improving the regulations


5. Method of calculationA report on the study of the impact of affordabilityassessment regulations on consumers withrecommendations

6. Data limitationsExpertiseUnclear TOR






12. Indicator responsibility Manager: Credit Provider Compliance

�*��+��;&��<�=��>��


Items (SO1) Guide

1. Indicator titleNumber of investigations/compliance monitoring/audits/raids/complaints evaluation conducted toenforce regulations.

��Enforcement of the Act through investigations, compliance monitoring and complaints evaluations.



• Referrals from other government entities • Proactive sourcing of information • Complaints received • Anonymous tip-offs • Media reports •�� "��"�� •�� < "�/��\��"��


•�Y��/��/��Y�� Consumer Tribunal (NCT) • Copies of compliance notices issued (signed compliance notices) •�U�� • Investigations reports • Complaints evaluations • Tip-off anonymous report



8. Calculation type Numbers

9. New indicator Continues with changes from the previous year



12. Indicator responsibilityManagers: Investigations and Enforcement, Complaintsand CP Compliance



Items (SO1) Guide

1. Indicator title

Enforcement action taken on a percentage (%) ofinvestigations/compliance monitoring/audits/raids/complaints evaluations conducted, where necessary for the whole year.

��Taking enforcement action against alleged non-compliance with the Act.



• Investigation reports • Compliance monitoring reports • Media reports •�� "��"�� •�� < "�/��\��"�� • Complaints evaluation reports


Total number of investigations/compliance monitoring/audits/raids/complains evaluations conducted for the whole year (where contraventions of the Act were found)

Total number of investigations/compliance monitoring/audits/raids/evaluation conducted for the whole year= Total percentage (%) of enforcement action taken

6. Data limitations Budget, resources and capacity








Items (SO1) Guide

1. Indicator titleA report on the impact study of the effect of total cost of credit and credit life insurance regulations on consumers.

��A study conducted on the effect of total cost of credit and credit life insurance regulations.


• Understanding the impact of the regulations on consumers and credit providers; and • Improving the regulations


5. Method of calculationA report on the impact study of the effect of total cost of credit and credit life insurance regulations on consumers with recommendations.







12. Indicator responsibility Manager: Statistics & Research


Items (SO2) Guide

1. Indicator title

Number of credit provider investigations/ compliance monitoring/audits/raids/complaints evaluations relating to reckless lending and/or collection of prescribed debt conducted to enforce regulations.

��To decrease the levels of non-compliance with provisions of the Act.

3. Purpose/importanceTo combat reckless credit granting and over-indebtedness.


• Referrals from other government entities • Proactive sourcing of information • Complaints received • Anonymous tip-offs • Media reports •�� "��"�� •�� < "�/��\��"��


•�Y��/��/��Y�� Consumer Tribunal (NCT) • Copies of compliance notices issued (signed compliance notices) •�U�� • Investigations reports • Complaints evaluations • Tip-off anonymous report




9. New indicator Continues without change from previous year




Items (SO2) Guide

1. Indicator title

Enforcement action taken on a percentage (%) ofinvestigations/compliance monitoring/audits/raids/complaints evaluations relating to reckless lending and or collection of prescribed debt where necessary for the whole year.

�� Enforcement of regulations through investigations


• Taking enforcement action against alleged noncompliance with the Act. • To decrease the levels of non-compliance with provisions of the Act.


• Investigation reports • Compliance monitoring reports • Media reports •�� "��"�� •�� < "�/��\��"�� • Complaints evaluation reports


Total number of investigations/compliance monitoring/audits/raids/complains evaluations conducted for the whole year (where contraventions of the Act were found)

Total number of investigations/compliance monitoring/audits/raids/evaluation conducted for the whole year Total percentage (%) of enforcement action taken

6. Data limitations •�Z�� ]��̂ ��+ "�� • Tribunal and Tribunal rules •�Y�� ;�"









Items (SO2) Guide

1. Indicator title

Number of multimedia awareness campaigns(radio/TV interviews/news print/communityoutreach programmes/social media) conducted on deceptive and unfair practices and consumer rights.

��Improving education awareness on the deceptiveand unfair credit practices and consumer rights.

3. Purpose/importanceTo educate and create public awareness for consumers on deceptive and unfair credit practices and consumer rights through multimedia awareness campaigns.


• Complaints received; • Investigations conducted; • Statistics; •�� • Media; • Stakeholder engagements.


• Media briefs; • News Clippings; • Interviews clips; •��]�{��"�� • Campaign reports; •��/��;�

6. Data limitations Training, capacity and funding





11. Desired performanceTo increase the level of public awareness ondeceptive and unfair credit practices.

12. Indicator responsibility Manager: Education & Communications

Items (SO3) Guide

1. Indicator titleNumber of credit bureaus monitored and disputesevaluated.


3. Purpose/importanceIncrease compliance by credit bureaus in respect of theirobligations in terms of the NCA.


• Form 43 annual reports • Credit bureau audited reports • Compliance monitoring plan • Media reports • Complaints evaluation reports


•�� "��L�� •�U�� • Compliance requirements letter sent to credit bureaus requesting information; •�* "��/��/��"��+ �� • Proof of compliance from credit bureaus;

6. Data limitations










Items (SO3) Guide

1. Indicator titleEnforcement action taken on a percentage (%) ofmonitored credit bureaus where necessary.

��Taking enforcement action on non-compliant credit bureaus.



• Form 43 annual reports; • Proactive sourcing of information; • Complaints received; • Anonymous tip-offs; • Media reports.


Total number of monitored non-compliant credit bureaus

Total number of monitored credit bureaus= Total percentage (%) of non-compliant credit bureaus

6. Data limitations








Items (SO3) Guide

1. Indicator titleNumber of audited reports submitted by registeredcredit bureaus and enforcement action taken wherenecessary.



4. Source/collection of data • Form 43 annual reports • Credit bureau audited reports • Compliance monitoring plan


•�� "��L�� •�U�� • Compliance requirements letter sent to credit bureaus requesting information; •��* "��/��/��"��+ ��

6. Data limitations










Items (SO3) Guide

1. Indicator title% of received credit bureau audited reports for ��!"�#��$��&��action taken where necessary.

��The indicator seeks to highlight non compliances �"��"�+�� "��"��+ ��


4. Source/collection of data • Credit bureau audited reports • Form 43 annual reports


• Received credit bureaus audited reports • Received completed Form 43 returns from credit bureaus • Referral memos to investigations department • Compliance notices issued; • Annual compliance review reports; • Approved internal memos.

6. Data limitations Z�� ]��̂ ��+ "��







Items (SO4) Guide

1. Indicator title% of uptime availability of the legacy ICT (Registrations and Complaints) systems.

��The indicator seeks to highlight the system availability ��/��

3. Purpose/importance�̀��/��"��"��

To assess the down time and uptime availability of thesystem

4. Source/collection of data Report from the systems.

5. Method of calculationICT network monitoring report (Registrations andComplaints ICT system)

6. Data limitations

• Non commitment of service provider, stakeholders��"\�� • Out-dated ICT hardware. • Capacity


8. Calculation type Percentage




12. Indicator responsibility ��



Items (SO4) Guide

1. Indicator title Approved service delivery improvement plan

��`��"��L��/��of the NCR

3. Purpose/importance To improve service delivery

4. Source/collection of data • Report from the systems • Performance information reports

5. Method of calculation Signed SDIP document

6. Data limitations

• Capacity • Expertise & budget • Resources (ICT systems) • Cooperation from the SDIP task team






12. Indicator responsibility Manager: Complaints department


Items (SO5) Guide

1. Indicator title

% of new applications registered in the consumer credit market within 10 business days of receipt of signed proposed conditions and payment of registration fees.

��`��"��L��/��registration process of persons and entities.

3. Purpose/importance �̀��/��

4. Source/collection of data • Registration fees collected; • Signed proposed conditions of registration received.


Total number of applications registered within 10 business days

Total number of applications registered= Total percentage (%) of new applications registered

6. Data limitations Training, capacity and ICT systems



9. New indicatorContinues without change from the previousyear.


11. Desired performanceIncreased number of registered persons andentities leading to job creation andestablishment of SMMEs.

12. Indicator responsibility Manager: Registrations

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