Regulatory Alerts2024-07-03
Change Management and the Risk of Over-indebtedness: Ten Principles and Seven Examples
The Dutch Authority for the Financial Markets (AFM) issued these ten principles to guide credit providers in establishing robust change management processes for IT and operational systems supporting consumer and mortgage lending. The document mandates that credit providers identify, assess, test, and monitor changes rigorously while maintaining fallback plans and promptly reporting incidents to regulators to prevent errors leading to over-indebtedness. It further illustrates these requirements through seven real-world incident examples where configuration errors, data mapping issues, or inadequate testing resulted in significant lending mistakes.
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