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Policy library

CBK DCP Regulations 2022 §4(3) — 6 mandatory pre-licensing policy documents

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1 document pending board approval — CBK package not yet complete

Per CBK DCP Regulations 2022 §4(3), all six policy documents must be submitted to CBK as part of the licence application. Submission of the package before data testing can accelerate licensing.

5

Board approved

1

Under review

6

Required (§4(3))

✗

CBK package ready

AML/CFT Policies and ProceduresBoard approvedv3.1

CBK DCP Regs §4(3)(a)

Anti-money laundering and combating financing of terrorism — customer due diligence, transaction monitoring, STR/CTR filing, OFAC/UN screening.

Approved by Board of Directors · 2026-03-15Next review: 2027-03-15

Data Protection Policies and ProceduresBoard approvedv2.0

CBK DCP Regs §4(3)(b) · DPA 2019 · ODPC Guidance Dec 2023

Data processing lawful basis, purpose limitation, data subject rights, breach notification within 72h, DSAR handling, retention and deletion schedules.

Approved by DPO & Board · 2026-04-01Next review: 2027-04-01

Consumer Redress MechanismsBoard approvedv1.2

CBK DCP Regs §4(3)(c)

Complaint intake, acknowledgement SLA (48h), escalation tiers, CBK referral path, cooling-off period for digital credit, dignity protection.

Approved by Board of Directors · 2026-02-20Next review: 2027-02-20

Credit PolicyUnder reviewv4.0-draft

CBK DCP Regs §4(3)(d)

Underwriting criteria, credit limits by product, concentration limits, forbearance framework, write-off authority matrix, IFRS 9 staging rules.

Awaiting board approvalNext review: 2026-07-31

Code of Ethics and Market ConductBoard approvedv1.1

CBK DCP Regs §4(3)(e)

Fair lending, responsible pricing, no predatory practices, staff conduct, conflicts of interest, whistleblower protection, market conduct standards.

Approved by Board of Directors · 2026-01-10Next review: 2027-01-10

Pricing Model and ParametersBoard approvedv2.3

CBK DCP Regs §4(3)(f) · CBK Guidance on DCP Pricing

Interest rate methodology, fee schedule, APR computation (inclusive of all charges), prepayment rules, penalty caps, pricing change notification period.

Approved by Board Risk Committee · 2026-05-01Next review: 2026-11-01

CBK submission guidance

All six documents must be submitted in the CBK licence application package

Documents must be board-approved (signed minutes required as annexure)

Credit policy must reference IFRS 9 staging and provisioning methodology

AML/CFT policy must reference CBK/AML §44 and Proceeds of Crime Act 2009

Pricing model must show APR including all charges per CBK DCP pricing guidance

Data protection policy must reference ODPC Guidance Note (December 2023)

Reference: CBK DCP Regulations 2022 §4(3) — Gazette Notice No. 12167 (23 Sep 2022)