One of the themes of the Abacus Convention was making the most of online marketing by effective conversion of website visitors (once they’ve found you) to customers.
For CUBS, that means how best to process an online application once you’ve got a prospective borrower to “click through”.
Are you really processing applications online in real time or just receiving some data online with the rest being done on paper?
From a legal point of view there are some key issues to consider with any solution including:
- credit assessment
- responsible lending
- satisfying disclosure obligations (both deposit, payment product and loan terms)
- satisfying record retention obligations
- satisfying electronic transaction requirements to ensure that a binding contract is entered online
- electronic signature requirements
- AML/CTF identification and risk requirements
- privacy issues
- ensuring that the person applying online is who they say they are
- meeting membership requirements, including age and shareholding.
And if the proposed solution is from a third party vendor, you may need the approval of your core banking system provider.
If you are looking at a solution, Bright law can advise you on the legal and contractual issues.
UPDATE: New Zealand Herald reports fraudulent online credit card applications made to Westpac.
