Verification methodology

01 — PurposeWhy a methodology exists

Words like verified, accredited and certified are used loosely in financial services, and a reader has no way of knowing which sense is meant. This page fixes one sense, narrowly, and publishes it before anything is issued — so that the standard cannot be quietly adjusted to fit whoever applies first.

Someone about to place capital is deciding about two things at once: an arrangement and the people behind it. The arrangement can be examined from documents. The people usually cannot, and the questions a careful reader would want answered — are they who they say they are, does a real organisation stand behind them, is anyone registered where registration is required, is there anywhere to complain — are exactly the questions a meeting is bad at answering.

02 — PrinciplesFour principles

1. Publish the criteria before the badge. A standard written after the first applicant is not a standard.
2. Record what was not checked. What a check omits is the part readers assume, so every record states it.
3. Separate money from findings. An assessment is charged for, because it is work. The fee buys the work and never the answer: it is the same whether the assessment passes or fails, it is published in advance, and it is not negotiable case by case. Partnership tiers, membership and dues are separate systems again, and no amount of any of them produces a status.
4. Date everything. A verification is a statement about a moment. Without a date and a review date it is decoration.

03 — OrganisationsWhat is checked: organisations

Legal identity

The registered name, registration number and trading names of the entity, confirmed against the companies register rather than against its own website.

Role in the process

What the organisation actually is in a transaction — platform, credit provider, administrator, issuer or adviser — stated precisely, because the role determines which rules apply to it.

Regulatory registration

Where the role requires a registration — a credit provider under the National Credit Act, a financial services provider under FAIS — the number, checked on the relevant public register and recorded with the date it was checked.

Public disclosure quality

Whether what the organisation publishes about risk, fees and the return of capital meets the Association's disclosure standards, judged against the material a member of the public would actually be shown.

Complaints route

That a member of the public can raise a complaint, that there is a named person or channel for it, and that a record of the outcome exists.

Code of conduct

A signed undertaking to the Association's code of conduct, and agreement to the publication of the verification record whatever it finds.

04 — PractitionersWhat is assessed: the baseline

Every applicant, whatever their role, is assessed against the same six baseline requirements.

Identity

The person or organisation is who they say they are, confirmed against identification or the companies register rather than against their own website.

Role stated precisely

What they actually do in a transaction — because the role decides which rules apply and which module is assessed.

Lawful basis to operate

Any registration or authorisation the role requires is held and confirmed on the relevant public register. Where none is required, that is recorded as not applicable with the reason.

Standing

No open disciplinary process, and nothing known that would require a record to be withdrawn. A statement about a record on a date.

Code of conduct

A signed undertaking to the code, and agreement to publication of the record whatever it finds.

A complaints route

A member of the public can raise a complaint, there is a named person or channel, and outcomes are recorded.

05 — Role modulesAnd then the module for the role

A fund manager, a security trustee and a commissioned introducer do different work and carry different risks. Assessing all of them against one test would produce a result that means nothing for any of them, so the baseline is followed by the module for the role. An applicant holding more than one role is assessed under each.

Commission disclosure and suitability appear in the origination module because that is where they apply. They are not universal rules of private lending, and presenting them as such would misdescribe most of the roles in the market.

06 — ApplyingApplying for an assessment

Verification is applied for. It is not conferred on an organisation because it is listed in a register, because it is a member, or because somebody on the Council has heard of it. An applicant asks to be assessed, is quoted the published fee, and is told the scope before anything begins.

1. Application. The applicant states which role or roles, and which models, the assessment is to cover. That becomes the scope, and the scope appears on the record.
2. Fee. The published assessment fee is payable before the work starts. It pays for the work. A refused application costs the same as a granted one, and the fee is not refunded on a refusal, because the assessment was performed either way.
3. Assessment. The baseline checks and the applicable role modules are carried out against the evidence supplied and the public record.
4. Decision. The decision is written down with reasons, granted or refused, and is confirmed by the Independent Reviewer before it is published.
5. Expiry. Every verification carries an expiry date on its face. It does not roll forward on its own.
6. Surveillance. Verification is maintained by annual surveillance, charged separately and at a published rate. A subject who declines surveillance expires; they are not removed, and the record says expired.

An assessment fee is payable for the work of the assessment and is not refunded if the assessment fails — a failed assessment costs exactly what a passed one costs. The proposed rates are published on dues and fees; they are not yet adopted and nothing is payable. Nothing on this page is charged for: the criteria, the methodology and every published record are free to read, and bringing a complaint is free.

07 — StatusesThe statuses a record can hold

The statuses a record can hold. None is currently held.

08 — PresentationWhat a verified profile shows

Every record, whatever it finds, carries the same fields in the same order:

1. Legal or professional identity.
2. Role in the private-lending process.
3. What was checked.
4. What was not checked.
5. Verification date.
6. Next review date.
7. Current status.
8. Relevant regulatory registration, where the role requires one.
9. The complaints or disciplinary route.
10. The limits of what verification covers.

Where a criterion does not apply, the record says so rather than omitting the line and letting a reader assume it was met.

09 — MaintenanceReview, withdrawal and appeal

• Review. Organisation records are reviewed annually and practitioner records are reconciled quarterly. The date of the most recent review is shown on the record.
• Withdrawal. A status is withdrawn when an agreement ends, when standing changes, or when a criterion can no longer be evidenced. Withdrawal is recorded as expired or suspended rather than deleted, because a record that quietly disappears tells a reader nothing.
• Challenge. Anyone may challenge a record — a subject, a reader or a member of the public — by writing to complaints@privatelendingassociation.co.za. Where a record is wrong it is corrected; where the challenge concerns conduct rather than accuracy, it is handled under complaints and review.
• Appeal. A subject may ask for a decision to be reconsidered, in writing, with the evidence they say was missed. The appeal route and the person who hears it will be named when the governance described on governance is in place. Until then the Council takes the decision, publishes the basis and the connection behind it, and refers it for re-examination once a Reviewer is appointed.

10 — BoundariesWhat verification does not mean

The Private Lending Association of South Africa is a voluntary industry association. It is not a regulator, a government body or a financial services provider.

The term used is verified rather than accredited. Accreditation implies a formal framework with its own governance, scope and appeal machinery. That does not exist yet, so the word is not used.

11 — CheckingHow to check a record yourself

1. Open the profile and read the status, the date and the list of what was not checked.
2. Take any regulatory number on the record and check it on the issuing register — the NCR register for a credit provider, the FSCA for a financial services provider.
3. Separately, ask which legal entity would receive your capital. That is a question about the arrangement, and no profile on this site answers it.
4. If anything on a record looks wrong, say so. Corrections are published, not quietly applied.

12 — QuestionsCommon questions

Has anyone been verified by the Association yet?

No organisation or practitioner has completed the verification review, so no record carries that status yet. Founding records are confirmed for ProLend and Wesley Thomson — that establishes identity and founding role, and nothing about competence, conduct or performance.

Does verification mean the Association approves a lending product?

No. Verification is a record about an organisation or a person — who they are, what role they play, what registrations they hold, what they disclose. It is not an assessment of any arrangement, product or opportunity, and the Association does not approve, endorse or rate those at all.

Does paying for a partnership tier affect verification?

No. Tiers and verification are separate systems, and the site is built so that one cannot imply the other. A partner that fails a check is recorded as failing it regardless of tier, and a tier can never be used to obtain or keep a status.

Is verification the same as being regulated?

No. The Association is not a regulator and has no statutory powers. Where a role requires a regulatory registration, verification records the number and the date it was checked, and points the reader at the public register so they can check it themselves. That register, not this site, is the authority.