CDC legal agreements require investees to operate in alignment with the SMART CPPs, which includes transparency of pricing in a form that can be understood. For retail institutions we do a customer risk review and test for gaps.

Pre-investment, compliance on this is assessed during due diligence; we also compare pricing to market benchmarks and look at loan to income ratios for clients. Where gaps are identified in advance of investment, mitigating actions are put into Action Plan to ensure this is carried out. In these cases, progress is monitored against action points every quarter by a responsible committee.

As above, alignment with the SMART Campaign CPPs are integrated into CDC legal agreements, thereby ensuring that terms and conditions are being communicated clearly to clients and at multiple stages throughout the loan approval process. The action plan and monitoring process described above are also applicable here.