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BNPL Responsible Lending Policy

RentPay Scorebuilder Product

1. Purpose

This policy outlines RentPay's (RentPay Technology Pty Ltd, ABN 68 636 254 709, ACL 541127) commitment to responsible lending for the RentPay Scorebuilder Product, a BNPL product under $500, ensuring compliance with applicable Australian laws and industry codes. While BNPL arrangements under $500 are considered low value, we recognise that poor lending practices can still lead to financial harm. This policy supports ethical, transparent, and responsible practices in offering and managing BNPL services.

2. Scope

This policy applies to all RentPay Scorebuilder transactions and covers staff, systems, and business practices involved in onboarding, approving, and managing customers who use these services.

3. Regulatory Framework

While BNPL under $500 may currently operate outside the full scope of the NCCP Act, this policy aligns with:

  • ASIC’s expectations for fairness and harm prevention.
  • The BNPL Code of Practice administered by AFIA.
  • Anticipated regulatory reforms to classify BNPL as a form of regulated credit.
  • The broader consumer protection provisions of the Australian Consumer Law (ACL).

4. Key Commitments

RentPay commits to:

  • Lending in a way that does not cause customer harm.
  • Keeping customers informed of their obligations and the risks.
  • Offering accessible support for hardship and vulnerable consumers.
  • Regularly reviewing processes to ensure effectiveness and compliance.

5. Suitability and Affordability Assessment

For RentPay Scorebuilder Product, we apply a proportionate approach to affordability checks:

Initial eligibility checks:

  • Identity verification (using secure KYC methods).
  • Age confirmation (18+ only).
  • Residency in Australia.
  • Active RentPay user and account.

Behavioural and transaction history checks:

  • Review of previous repayments (if a returning customer).
  • Automated system flagging for recent late or missed payments.

No formal income verification is required for <$500 products, but we may:

  • Apply internal heuristics to detect possible over-commitment.
  • Decline approval where there are indicators of financial stress (e.g., repeated shortfalls, multiple concurrent BNPL debts).

Full credit check at a registered credit bureau

  • Review of current credit commitments.
  • Historical behaviour regarding credit commitments, with a specific focus on SACC commitments.
  • Credit score.
  • Hardship flags or indicators.

6. Credit Limit and Product Controls

  • Default spending limits are capped and may only increase with positive repayment history.
  • Credit limits are not automatically increased, there is an application, assessment and verification process.
  • We do not allow concurrent open RentPay Scorebuilder Product agreements beyond a set internal risk threshold.

7. Transparency and Disclosure

We ensure customers clearly understand:

  • The total repayment amount.
  • Payment schedule and due dates.
  • Late fees and consequences of missed payments.
  • Contact details for hardship support and complaints.

Information is provided:

  • Upfront (before agreement is entered into).
  • In plain language.
  • Accessible via digital and customer service channels.

8. Hardship and Vulnerability Support

We provide an accessible and fair hardship program, including:

  • Temporary payment deferrals or extensions.
  • Waiving late fees for customers in genuine hardship.
  • Directing customers to financial counselling services (e.g., National Debt Helpline).

Staff are trained to:

  • Identify signs of vulnerability (e.g., family violence, illness, financial distress).
  • Offer empathetic, non-judgemental support.
  • Escalate cases where specialist support is needed.

9. Complaints and Dispute Resolution

We maintain:

  • A responsive internal dispute resolution (IDR) process aligned with ASIC Regulatory Guide 271.
  • External dispute resolution via AFCA.
  • Clear communication to customers about their right to complain and how to escalate unresolved issues.

10. Staff Training and Conduct

All staff involved in the Scorebuilder operations receive training on:

  • Responsible lending practices for small-value credit.
  • Recognising and managing vulnerable customers.
  • BNPL Code of Practice compliance.
  • Customer-first behaviour and ethical standards.

11. Monitoring and Continuous Improvement

We will:

  • Regularly review transaction data and repayment behaviour.
  • Conduct internal audits of BNPL assessments.
  • Actively monitor customer feedback and complaint trends.
  • Adapt policies in line with legislative or industry changes.

12. Governance and Compliance Oversight

  • The Compliance and Risk team ensures ongoing adherence to this policy.
  • Significant breaches or trends are reported to senior management and, where required, the regulator.
  • This policy is reviewed annually or sooner if there are material regulatory changes.