The NCR’s Guideline for the Submission of Credit Information in Terms of Regulation 19 (13) of the National Credit Act 34 of 2005, as Amended.
On 23 June 2017, the National Credit Regulator (NCR) published a Guideline  prescribing that all credit and data providers (collectively called ‘data contributors’) are required to submit credit information to all duly registered credit bureaux.
The guideline names the South African Credit and Risk Reporting Association (SACRRA), in conjunction with the Credit Bureau Association (CBA) as the institutions managing the supply of credit information, via a secure data transfer portal. This portal is known as the Data Transmission Hub (known in the industry as ‘the Hub’) and is overseen by SACRRA and is jointly owned with the CBA.
The guidelines aim to ensure that when a data contributor accesses information from the bureaux, the data contributor must also submit data to the bureaux. This is called reciprocity.
More specifically, data contributors who access payment profile information, mustcomply with the data sharing requirements of the National Credit Act (NCA). Failure to comply will result in access to all payment profile information being denied.
Regulation 19 (13) of the NCA states that “A data contributor must submit credit information to the credit bureaus in the manner and form prescribed by the National Credit Regulator through conditions of registration and any guidelines that may be issued by the National Credit Regulator from time to time.”
This new Guideline Regulation outlines the method and manner  in which data files should be submitted to the credit bureaux. The method is via the hub, while the manner is via the L700v2 Data Specification (a layout according to which data fields must be completed).
What does this mean for data contributors? If a data contributor is already a SACRRA member, or if they utilise a Secondary Service Provider (SSP) or Loan Management System Vendor (LMSV) to manage the submission of their data, such data contributors may continue to report data as per their existing processes. There is no need for additional measures to be put in place.
If the data contributors are non-SACRRA members, they will be required to undergo a “provider of credit information assessment”. This assessment determines in which category a data contributor will be placed, in terms of development, testing, and a roll-out plan.
All non-SACRRA members should take note that they have until 31 October 2017 to undergo the assessment, which carries a once-off cost of R500 excluding VAT , as prescribed by the NCR. This fee is payable to SACRRA and may be collected by the bureaux on the data contributor’s behalf. Failure to pay the assessment fee will cause the data contributor to be excluded from the roll-out plan, as the assessment will be deemed incomplete. This may mean that the data contributor is not complying with its obligations to submit the data as required by Reg 19(13).
The assessment will determine the following:
- Whether a data contributor is in fact a provider of information which falls within the ambit of the National Credit Act
- What the on-boarding timetable of a data contributor will be, subject to the data format development and readiness schedule
- The volume of credit information that the data contributor should submit to the credit bureaux
In addition, a monthly fee may be levied by SACRRA for use of the hub, and payment of this fee can be processed by Compuscan.
Kindly take note that failure to comply with the NCR’s Guideline in terms of Regulation 19 (13) of the Act will result in a business being non-compliant with the provisions of the Act, as well as the terms and conditions of registration. This may result in a notice of non-compliance being issued against the business by the NCR, or by the business’ registration with the NCR being cancelled.
Regulation 19 (13) therefore not only provides for the submission of data to a central hub, it also provides for the specification of parameters for data extract submission and updating. This ensures that logical, complete and up-to-date information is loaded and correctly aged on credit bureaux.
The promulgation of the Regulation 19 (13) Guidelines is a much-needed solution to numerous reports to the NCR, concerning the non-submission of data by certain data contributors, as well as poor quality data or erroneous submissions.
The hope is that these new measures, and the requirement for compliance with the provisions of the Act and its terms and conditions will lead to the submission of accurate, high-quality data to all credit bureaux in the future.
Should a business require more information on the NCR’s Guideline for the submission of Credit Information in terms of Regulation 19 (13) of the NCA, they should contact the NCR via the details on www.ncr.org.za, or SACRRA as per the details on www.sacrra.org.za