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Укр Outsourcing of NFIs in a new way: the AUB Committee on Non-Banking Lending discussed the regulator's innovations
On May 16, the Non-Bank Lending Committee of the Association of Ukrainian Banks (AUB) held a meeting to discuss outsourcing issues in accordance with the Law of Ukraine “On Financial Services and Financial Companies”.
The event was attended by more than 30 representatives of non-bank financial institutions (NBFIs), who had the opportunity to receive comprehensive answers to topical issues related to outsourcing, in particular:
Necessity and format of the NBU notification on outsourcing:
Clarification of the NBU's requirements for outsourcing key functions, such as collection services.
List of information to be included in the outsourcing notification.
Practical examples of filling out the outsourcing notification.
Duplication in the outsourcing notification process:
Discussion of duplication of outsourcing notification requirements in different legal acts.
Possible ways to optimize the outsourcing notification process.
Uncertainty regarding outsourcing of credit services:
Clarification of whether the use of credit bureaus for risk assessment is considered outsourcing.
Recommendations for further actions to obtain official clarifications from the NBU.
During the meeting, DBA representatives and Committee members provided several recommendations to non-bank financial institutions to improve their work in view of the new regulatory norms.
In particular, the recommendations included:
Familiarization with the NBU's letters on outsourcing and bringing NFIs' activities in line with them.
Use of the updated DIA guidelines on outsourcing, which will contain a clear indication of the need to notify the NBU of collection services provided by third-party companies.
Contacting the DBA for assistance in establishing communication with the NBU on outsourcing issues.
Sergiy Sinchenko, Chairman of the Non-Banking Lending Committee, thanked the NBU for its effective communication with the Association - the regulator's letters and explanations have certainly become a valuable guide for non-bank financial institutions. The Head of the CBA Committee also noted that a number of issues related to outsourcing remain unclear.
In particular, it is not fully defined whether the use of credit bureaus for risk assessment is considered outsourcing. This issue is important for many NFIs, as it affects whether they need to notify the NBU of such services. There are also questions about the format of the information provided to the regulator, in which outsourcing is reported. Therefore, given the relevance of these issues, the DBA plans to apply to the NBU for additional information and official clarifications.
“We are convinced that a clear understanding of the regulator's requirements for outsourcing will contribute to the transparency and efficiency of the non-banking financial sector,” said the Chairman of the Non-Banking Lending Committee.
“Today's meeting of the Non-Banking Lending Committee of the Association of Ukrainian Banks is an important platform for discussing topical issues related to the regulation of non-bank financial institutions. In particular, today we considered important issues regarding innovations in outsourcing, discussed practical recommendations for NFIs. The CBA will continue to actively cooperate with the National Bank of Ukraine and its members - non-bank financial institutions - to ensure a clear understanding of and compliance with the regulator's requirements for outsourcing,” summarized CBA President Andriy Dubas.
