{
  "service": "Creditcrest Compliance",
  "version": "1.0.0",
  "not_an_opinion": "This reports what the lender recorded against the gates, controls and obligations it named. It is not a compliance opinion or legal advice, and it does not say that a control meets an obligation. Creditcrest Technologies is not a credit provider, is not a credit assistance provider, and does not hold an Australian credit licence. Its software produces evidence; the licensee makes the decision.",
  "stores": "nothing",
  "required_gates": {
    "credit licence": "The Australian credit licence — or the authority of a licensee — under which the credit is provided.",
    "legal review": "Contracts, disclosures and customer documents reviewed by the lender’s lawyers.",
    "risk approval": "The credit policy and the risk appetite approved by whoever the lender says approves them.",
    "mandatory tests": "The tests the lender requires before release, run and passed.",
    "security assurance": "The security review the lender requires, done and passed.",
    "provider readiness": "Every outside provider — identity, bank data, payments, signing, messaging — contracted and cleared for production.",
    "activation": "The person the lender names as able to switch production on has done so."
  },
  "capabilities": {
    "application intake": "Taking real applications.",
    "contract delivery": "Sending contracts for signature.",
    "signature webhook": "Acting on a signing provider’s notice that a contract was signed.",
    "disbursal": "Advancing money.",
    "payment collection": "Collecting repayments.",
    "email": "Sending email to applicants and borrowers.",
    "sms": "Sending text messages.",
    "credit check": "Requesting credit reports.",
    "bank data": "Retrieving bank data.",
    "identity check": "Verifying identity documents and the person holding them."
  },
  "modes": [
    "prelaunch",
    "sandbox",
    "production"
  ],
  "evidenced": [
    {
      "id": "ninety-days",
      "cite": "National Credit Act s 130(1A)",
      "quote": "If: (a) the credit contract is a small amount credit contract; and (b) the consumer holds (whether alone or jointly with another person) an account with an ADI into which income payable to the consumer is credited; the licensee must, in verifying the consumer’s financial situation for the purposes of paragraph 128(d), obtain and consider information about each transaction on the account, and the balances of the account, during at least the immediately preceding period of 90 days.",
      "product": "Creditcrest Statement",
      "evidence": "The reading of at least ninety days of transactions and balances, with the period stated."
    },
    {
      "id": "protected-earnings",
      "cite": "National Credit Act s 133CC(1)",
      "quote": "A licensee must not enter into, or offer to enter into, a small amount credit contract with a consumer who will be the debtor under the contract if the repayments that would be required under the contract would not meet the requirements prescribed by the regulations.",
      "product": "Creditcrest Small Amount",
      "evidence": "Every repayment period tested against 10% of available income, the tightest named."
    },
    {
      "id": "establishment-fee-cap",
      "cite": "National Credit Code s 31A(2)",
      "quote": "A permitted establishment fee is a fee or charge the amount of which must not exceed 20% of the adjusted credit amount in relation to the small amount credit contract.",
      "product": "Creditcrest Small Amount",
      "evidence": "The fee against 20% of the adjusted credit amount."
    },
    {
      "id": "monthly-fee-cap",
      "cite": "National Credit Code s 31A(3)",
      "quote": "The amount of a permitted monthly fee that may be imposed or provided for under a small amount credit contract must not exceed 4% of the adjusted credit amount in relation to the contract.",
      "product": "Creditcrest Small Amount",
      "evidence": "The fee against 4% a month."
    },
    {
      "id": "unexpired-monthly-fee",
      "cite": "National Credit Code s 31C(1) and (2)",
      "quote": "A credit provider must not require or accept payment by the debtor under a small amount credit contract of an unexpired monthly fee. … An unexpired monthly fee in relation to a small amount credit contract is each permitted monthly fee that is in respect of a month that commences after the date on which the contract is paid out.",
      "product": "Creditcrest LoanManager",
      "evidence": "No monthly fee charged after payout, from the ledger."
    },
    {
      "id": "default-ceiling",
      "cite": "National Credit Code s 39B(1) and (3)",
      "quote": "If there is a default in payment under a small amount credit contract, the credit provider in relation to the contract must not (whether by repayments under the contract or otherwise) recover more than twice the adjusted credit amount in relation to the contract. … This section does not apply to enforcement expenses.",
      "product": "Creditcrest LoanManager",
      "evidence": "What was charged against twice the adjusted credit amount, once in default."
    },
    {
      "id": "equal-repayments",
      "cite": "National Credit Act s 133CD(1) to (4)",
      "quote": "A licensee must not enter into, or offer to enter into, a small amount credit contract with a consumer who will be the debtor under the contract if any of the following applies: (a) repayments that would be required under the contract are not equal; (b) the intervals between repayment dates would not be equal; (c) the interval between the date on which credit would be first provided under the contract and the first repayment date would be longer than twice the interval between the first repayment date and the second repayment date. … repayments … are taken to be equal if: (a) each repayment is of the same amount; or (b) both of the following apply: (i) each repayment (other than the last repayment) is the same amount; (ii) the last repayment is up to 5% less than each other repayment … if a small amount credit contract provides that: (a) repayments … are to be made on or by a fixed day of each week, fortnight or month; and (b) if that fixed day falls on a day that is not a business day—the repayment would be required to be made on or by the immediately preceding or succeeding business day; the intervals between repayment dates are taken to be equal.",
      "product": "Creditcrest Small Amount",
      "evidence": "The repayment schedule tested for equal amounts and intervals."
    },
    {
      "id": "hardship-notice",
      "cite": "National Credit Code s 72(1)",
      "quote": "If a debtor considers that he or she is or will be unable to meet his or her obligations under a credit contract, the debtor may give the credit provider notice (a hardship notice), orally or in writing, of the debtor’s inability to meet the obligations.",
      "product": "Creditcrest Collections",
      "evidence": "The statutory clock a hardship notice starts, with every period’s provision."
    },
    {
      "id": "requirements-objectives",
      "cite": "National Credit Act s 130(1)(a)",
      "quote": "For the purposes of paragraph 128(d), the licensee must, before making the assessment: (a) make reasonable inquiries about the consumer’s requirements and objectives in relation to the credit contract",
      "product": "Creditcrest Apply",
      "evidence": "The reasonable inquiries record: each question on purpose, amount, term and features, in the words asked, with the answer and the form version, sealed."
    },
    {
      "id": "financial-situation",
      "cite": "National Credit Act s 130(1)(b)",
      "quote": "For the purposes of paragraph 128(d), the licensee must, before making the assessment: … (b) make reasonable inquiries about the consumer’s financial situation",
      "product": "Creditcrest Apply",
      "evidence": "The reasonable inquiries record: income, employment, housing, expenses, other credit and commitments, household, assets and foreseeable changes asked and answered, each declared figure beside the statement’s, sealed. A form that leaves a required topic unasked is refused unless its reason is recorded and signed off by a second person."
    },
    {
      "id": "assessment-copy",
      "cite": "National Credit Act s 132(2)",
      "quote": "If, during the period that: (a) starts on the day (the credit day) the credit contract is entered or the credit limit is increased; and (b) ends 7 years after that day; the consumer requests the licensee for a copy of the assessment, the licensee must give the consumer a written copy of the assessment: (c) if the request is made within 2 years of the credit day—before the end of 7 business days after the day the licensee receives the request; and (d) otherwise—before the end of 21 business days after the day the licensee receives the request.",
      "product": "Creditcrest LoanManager",
      "evidence": "The day a requested copy of the assessment is due, in business days."
    },
    {
      "id": "precontractual-disclosure",
      "cite": "National Credit Code s 16(1) and (2)",
      "quote": "A credit provider must not enter into a credit contract (other than a low cost credit contract) unless the credit provider has given the debtor: (a) a precontractual statement setting out the matters required by section 17 to be included in the contract document; and (b) an information statement in the form required by the regulations of the debtor’s statutory rights and statutory obligations. … Those statements must be given: (a) before the contract is entered into; or (b) before the debtor makes an offer to enter into the contract; whichever first occurs.",
      "product": "Creditcrest LoanManager",
      "evidence": "A contract refused for sending until both statements are recorded as given."
    },
    {
      "id": "contract-copy",
      "cite": "National Credit Code s 20(1) and (2)",
      "quote": "If a contract document is to be signed by the debtor and returned to the credit provider, the credit provider must give the debtor a copy to keep. … A credit provider must, not later than 14 days after a credit contract is made, give a copy of the contract in the form in which it was made to the debtor.",
      "product": "Creditcrest LoanManager",
      "evidence": "The day a copy of the contract as made is due."
    }
  ],
  "endpoints": {
    "POST /v1/compliance/readiness": "{gates: [{key, status, attestedBy, attestedOn, evidence, expiresOn, mandatory}], asAt, environment?, required?}",
    "POST /v1/compliance/capabilities": "{mode, enabled: [...], approvals: {legalLaunch, creditLicence, afcaMembership, providersProduction}}",
    "POST /v1/compliance/changes": "{requests: [{id, control, change, requestedBy, approvedBy, approvedOn, rejectedBy}], approvers: [...]}",
    "POST /v1/compliance/traceability": "{matrix: {obligations, controls, tests, evidence}, asAt}",
    "POST /v1/compliance/target-market": "{tmd: {criteria, channels, reviewEveryDays, triggers}, facts, channel, asAt, metrics}"
  }
}