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Does the National Credit Act stop the rot?

13 May 2010 | Credit | General | Gareth Stokes

The National Credit Act (NCA) was lauded as ‘a saving grace’ for South Africa’s indebted consumer. It lives up to its promise by ensuring that lenders perform the necessary ‘affordability’ checks before extending credit, and by creating mechanisms (such as the debt counselling process) to assist defaulters. The Act has been welcomed as one of the most comprehensive consumer protection legislations in the world. Is everything as rosy as the lenders and legislators would have us believe?

Although the Act protects consumers from unscrupulous lending practices it does little to curtail the fees and interest charges levied by banks and other credit providers in exchange for their services. If anything the quantification of maximum fees and interest charges in the legislation has bolstered the bottom line of banks, mortgage originators and other credit providers. Why do we say this?

Charging the maximum the Act allows

Finance houses used to earn their money by charging interest on the principal amount of your debt. In the past you could finance your home or vehicle with reasonable up-front fees and a minimal monthly service charge. It seems the NCA was ‘hijacked’ by finance houses which carved out lucrative initiation fees and service charges within its pages. Lenders – already coining it by way of interest charges – can make thousands more by billing (in our view excessively) for various administrative activities. And they can make even more by including some of these charges in the principal debt!

Banks and other mortgage lenders can, for example, charge an initiation fee of R1 000 per agreement (plus 10% of the value of the principal loan in excess of R10 000) up to a maximum R5 000. That’s what they take for pressing ‘go’ once the loan agreement is in place. Remember they charge separate fees – such as a valuation fee – over and above this amount. Credit facilities and ‘unsecured credit transactions’ can levy an initiation fee of R150 per contract plus 10% of the agreement in excess of R1 000. Mark our words – this ‘maximum’ is usually applied as a rule!

A vehicle finance agreement collects R1 000 (ex VAT) at inception – and your bank will hit the R5 000 limit for home loan initiations too. Given the typical loan value it hardly matters that the Act restricts initiation fees to a maximum of 15% of the principal debt! If you’ve checked your home loan or hire purchase statement you will also notice a monthly service charge, typically also levied at the legislated maximum of R50 (ex VAT) per month. If you dare question the dealer or bank agent about these fees they simply shrug and mumble something like: “It’s stipulated in the NCA.” Stipulated indeed – it’s a suggested maximum – not a legislated charge as they suggest!

And then things get really expensive

Our brief investigation into the fees and interest charged on mortgages, hire purchase and other credit agreements was inspired by an email from a regular reader. The reader wondered what rates a loan company could justify on a short term credit agreement. He might be shocked by the answer. The maximum allowable interest rates and fees are stipulated in Chapter 5 of the Usury Act of 1973 (as amended), with the NCA referring to the Usury Act for such charges.

The Act prescribes maximum rates for lenders across a number of categories – all loosely based on the Reserve Bank’s repo rate (RR). So, for example, a mortgage lender can charge a maximum [(RR x 2.2) + 5%)] per annum. With RR at 6.5% (since 26 March 2010) any of the ‘big four’ banks can charge a maximum 19.3% per annum on mortgage loan. Fortunately competition in the mortgage lending space keeps the banks in check and your typical mortgage is within a percent of the prime mortgage rate, set at 10% since 26 March 2010.

If you’re in the market for short-term credit the story is entirely different. Such instruments carry a maximum interest charge of [(RR x 2.2) + 10%] per year, or 24.3% per annum. And lenders can charge a maximum of 34.3% per annum for unsecured transactions. An ‘unsecured credit transaction’ is clearly defined as a credit transaction in respect of which the debt is not supported by any pledge or other right in property or surety or any other form of personal security. But the real shock relates to so-called ‘short-term credit transactions’ – defined as a deferred amounts not exceeding R8 000 that will be settled within six months – which can attract monthly interest rates of 5%!

Banks and other credit providers coining it

How much profit does a standard mortgage lender rake in? We base our calculation on a typical home loan of R1m, no deposit and 10% interest fixed for 20-years. Under this scenario a typical local mortgage lender will bank R5 000 in initiation fees, R12 000 in monthly service fees and a whopping R1.3m (or more) in interest – all sanctioned by the NCA. And this doesn’t include the profit they make by selling your home owners and life insurance as part of the transaction.

An unsecured loan is even more profitable. A small lender that extends R50 000 over three years (at the maximum 34.3%) will bank R1 000 in initiation fees, R1 800 in monthly service fees and at least R33 000 in interest. And we have a sneaking suspicion some of the country’s ‘unsecured’ lenders are forcing you to ‘secure’ the transaction by taking out credit life insurance... Makes you think doesn’t it!

Editor’s thoughts: South African consumers must become more aware of their rights when entering mortgage and hire purchase agreements. Although the banks and other providers claim their initiation fees are ‘legislated’ they are actually charging the maximum allowed by the law. Does the NCA contravene competition laws by legislating maximum allowable fees and interest rates? Add your comment below, or send it to [email protected]

Comments

Added by Alfred, 25 May 2015
I am in the same predicament, R5700.00 is included in the pricipal debt plus insurance 1341.11. Above all this they want the R5700.00 to be paid upfront. This is robbery and it is permitted by NCR. The interest is already included of the intiation fee in interest. Why?
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Added by Johan Wepener, 28 Mar 2015
Hi
A non paid medical account of R350 by my daughter has accumulated to R3000 in six months, despite her paying on it.....is it really legal?
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Added by Daniela, 29 Nov 2010
I have a friend who needed money desparetdly and borrowed R3700 in July 2010 from a money lender working in a big retal shop next to her place of work. She paid R1800 in Aug, R2400 in Sept and R2700 in Oct. The money lender wants her to pay R2850 with interestsbeing 1425 which adds up to R4275 thus the whole amount that has to be repaid is R11175. She approached me for advice and I am reading up on the Usury and Nat Cedit Act but am still unsure what to advise.Please assist or refer me.
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Added by woulduknow, 30 Jul 2010
If at the time of the short term loan the interest rate charged was below the prescribed maximum interest rate, but is now above due to rate decreases, do the banks have adjust the interest rate down on the existing loan?
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Added by Mandla, 16 May 2010
Excellent article ...whilst there is some competition to challenge the banks on the secured lending side it is on the unsecured lending side in which the majority of South African's are exposed (and unashamedly solicited to) that is most worrying. I don't think Adam Smith ever envisaged the extent to which rampant capitalism could serve to widen the Gini Coefficient (index between have's and have nots) to the extent that it has. Indeed our government should be called to act in support of the Constitution to protect the proletariat who put them in power in the first place.
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Added by Mike, 14 May 2010
Very useful, thanks Gareth - as corporate brokers with a lot of blue collar employees, we see payrolls overloaded with garnishee orders and 'ordinary' consumers drowning in "small debts" that were 'handed over' to debt collectors and lawyers. Invariably, these so-called "short term" debts (balances on cell phones, medical accounts, Woolworths, Edgars etc) are then charged 5% interest pm plus charges - and just try to get a balance statement out of them ! Some of our biggest "securitization" companies have grown up from milking the Edgars debt book for over a decade - and there is scant regard for law, which does not permit them to change the interest rates. It's interesting to read what the following professionals advised: (1) A handed over medical account is an incidental credit agreement subject to a 2% per month maximum prescribed interest rate. In terms of collection costs the maximum is R350.00 per amount excluding vat that has been collected and the total amount is not capped. This is in accordance with Regulation 47 of the NCA read together with various Acts depicted in Sub section (b). (Jenny Rossouw for HANNATJIE VAN DER MERWE ATTORNEYS) (2) • Attorneys and debt collectors can only collect in terms of the original agreement between credit provider and consumer. No legal practitioner or debt collector may collect any capital amount or amend the interest rate on other terms than been discussed and agreed to between the parties involved. Only the terms stipulated in the original agreement apply. • Any debt collector and/or securitization firm has the obligation to provide the debtor with a detailed statement concerning capital, interest, costs and fees. If such party refuses to hand a consumer such statement, the consumer can report such party to their local Law Society, the Association of Debt Recovery Agents (ADRA) and as last resort, the National Credit Regulator. (Source: Micro Finance SA) Amazingly, garnishee and court orders seem to be issued with impunity that breach these restrictions - with the result that lower earners keep on paying off the same "small debts" for years. I think the NCA is a flop - it doesn't protect those who need it most.
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Added by Mike Chong, 13 May 2010
This is an excellent article and scary. It cannot be passed of as unintended consequences either because with the resultant sophisticated legislation, surely ther should have been some intelligent people that followed the process to the final Act?These numbers are just to frightening. I would probably never ever go for another bond and have to buy my cars for cash! Surely their is a way for the Ministry of Finance or responsible body to review this situation? It's no wonder the citizens of this country are perpetually enslaved!
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Added by Chrisj, 13 May 2010
Cant agree more with the article. I noticed sometime back that finance houses just stick in the initiation fee at the max. Try and get them to reduce this and see the reaction.."its in the Act." Even their own staff dont know that this is just the max they can charge, doesn't mean thats what they must do. Its the old "take it or leave it" attitude which is thrown at consumers. The other cost that has crept in as far as motor finance concerned...."Licensing costs" on average R3500 a pop. New car? Then buy a second hand car, no new plates, no new disc, nothing and the costs are still the same. Then try saying u will go and do it yourself and save the R3500 and see the reaction u get...to me another way to get comm to yr salesman!
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