Instruction No. 001-DDI/2019 Setting the Application Modalities of Law No. 2017-045 of February 15, 2018 Governing the Activity and Supervision of Credit Information Bureaus

BANKY FOIBEN'I MADAGASIKARA DIRECTION DE LA DOCUMENTATION ET DES CENTRALES D'INFORMATION

INSTRUCTION N° 001 -DDI/2019 Setting the Application Modalities of Law No. 2017-045 of February 15, 2018 Governing the Activity and Supervision of Credit Information Bureaus

The Governor of Banky Foiben'i Madagasikara,

Having regard to Law No. 2014-038 of January 9, 2015 on the protection of personal data;

Having regard to Law No. 2016-004 of July 29, 2016, supplemented by Law No. 2016-057 of February 2, 2017, establishing the statutes of the Central Bank of Madagascar;

Having regard to Law No. 2017-018 of December 19, 2017 governing the Integrated Information System of Banky Foiben'i Madagasikara;

Having regard to Law No. 2017-045 of February 15, 2018 governing the activity and supervision of Credit Information Bureaus;

Having regard to Decree No. 2014-1684 of October 29, 2014 appointing the Governor of the Central Bank of Madagascar;

DECIDES

Article 1. OBJECT AND SCOPE OF APPLICATION This Instruction aims to set the application modalities of Law No. 2017-045 of February 15, 2018 governing the activity and supervision of Credit Information Bureaus, abbreviated as BIC. Its provisions apply to entities supervised by BFM or CSBF, on the one hand, and to the BIC, on the other.

TITLE I - DATA SUPPLIERS

Article 2. LIST OF DATA SUPPLIERS In application of Article 2 of Law No. 2017-045 of February 15, 2018, the following entities are qualified as Credit Data Suppliers: supervised (i) and non-supervised (ii):

(i) Supervised entities

• Credit institutions as governed by the banking law,
• Microfinance Institutions (IMF) governed by Law No. 2017-026 of December 7, 2017 on Microfinance,
• and other supervised entities having the status of data suppliers by virtue of a law in force.

(ii) Non-supervised entities

• Private or public water and electricity distribution companies operating on national territory;
• Companies providing telecommunications services;
• Automobile dealers;
• Large distribution companies making credit sales;
• Companies offering hire-purchase services;
• Satellite channel distributors;
• Entities referred to as "non-subject to" provided for in Article 2 of Law No. 2017-026 of February 8, 2018 on Microfinance;
• All companies granting payment facilities.

Article 3. SUBMISSION 3.1. In their capacity as Data Suppliers, the entities listed in Article 2 above are required to comply with the provisions of Law No. 2017-045 of February 15, 2018 governing the activity and supervision of Credit Information Bureaus. 3.2. The modalities for data submission and information consultation are described in the code of conduct agreed between the BIC and supervised entities and previously approved by BFM or, where applicable, in the membership contract established between them. 3.3. In application of Article 38 of Law 2017-045 of February 15, 2018, entities supervised by BFM and CSBF are required to submit to the BIC monthly declarations of credit data having obtained the consent of borrowers before the 10th of the following month.

TITLE II - CONTROL OF BICS BY BFM

Article 4. REPORTING TO BFM 4.1. In the context of desk audits conducted by BFM, a duly approved BIC is obliged to send to BFM, 10 days at the latest after the end of each month, a monthly report or reporting whose form and content are described in ANNEX A of this instruction. In application of Article 22 paragraph 3 of Law 2017-045 of February 15, 2018, the copy of the certified financial statements of the BIC for the past fiscal year and the report of the auditor(s) related thereto must be sent to BFM at the latest 30 days from the date of approval of the accounts.

4.2. During on-site or on-premises audits conducted by BFM, the BIC as well as all Data Suppliers and Users must be able to present all necessary documents required for the accomplishment of its mission as defined by Article 6 of Law No. 2017-045 of February 15, 2018.

Article 5. SUBMISSION MODALITIES The submission of reporting must be done by all means and supports ensuring the integrity and reliability of documents. After verification of the completeness of the files, an acknowledgment of receipt is issued by BFM to the submitter.

TITLE III - DATABASE TRANSFERS IN CASE OF CESSATION OF ACTIVITIES OF A BIC

Article 6. OBLIGATION OF TRANSFER A BIC that ceases its activities according to the provisions of Article 13 of Law No. 2017-045 of February 15, 2018, is required to proceed with the transfer of its entire database and backup copies to BFM.

Article 7. TRANSFER DEADLINE The entire database of the BIC as well as the usable backup copies must be submitted to BFM within a period of one (1) month at the latest, from the notification of the decision of suspension or withdrawal of approval.

Article 8. TRANSFER MODALITIES The modalities and technical details relating to the transfer of data are defined by mutual agreement between the concerned BIC and BFM. They take into account the security of data at rest stored at the level of the BIC and in transfer. The two parties must ensure that the transferred data can no longer be restored or reused both on the main site and on the BIC's backup site.

TITLE IV - TARIFF GRID

Article 9. PRESENTATION OF THE GRID BY THE BIC In application of Articles 32 and 44 of Law No. 2017-045 of February 15, 2018, the tariff grid relating to services provided by the BIC below are subject to homologation by BFM:

• services with mandatory consultation;
• services provided for in the business plan provided by the BIC at the time of the approval request. Services agreed upon freely between the BIC and a Data User are excluded from the application of this article.

Article 10. HOMOLOGATION MODALITIES BY BFM 10.1. The tariff grid accompanied by an explanatory note on the price structure must be communicated to BFM, at least, 2 months before the operationalization of the BIC and at least 1 month before any modification. An official request, indicating the proposal or modification of the tariff grid, must be filed by the BIC with BFM for homologation. The presented grid must highlight the different components of the different tariffs for each service to be provided.

10.2. BFM reserves the right to consult the various Professional Associations of Credit Institutions and other Data Suppliers to collect their opinions, and the right to have additional information communicated by the BIC or by other stakeholders in the credit information sharing system.

10.3. A certificate will be issued by BFM within a maximum period of 30 days in favor of the BIC whose service tariffs have received its homologation. In the absence of notification by BFM within the prescribed period, the proposed tariffs are considered homologated.

10.4. The BIC communicates this homologated tariff grid to BFM by specifying its effectiveness by sending a copy of the display, to the Professional Associations of supervised entities and other Data Suppliers.

10.5. The homologated tariff grid is brought to the attention of the public with the certification of BFM by display in the premises of the BIC.

Article 11. MODIFICATION OF THE TARIFF GRID Any modification of the tariff grid must be the subject of an official motivated request to BFM for homologation according to the modalities provided for in Article 10 and must include the new components of the tariffs to be modified.

TITLE V - RIGHTS OF DATA HOLDERS

Article 12. OBTENTION OF CONSENT 12.1. Supervised Entities must obtain the free, informed, and explicit consent of their Client before any collection and use, any sharing and dissemination of personal data, including credit information. The Client's consent may take the form of:

• an independent written document, or included in another document such as a credit application, or terms and conditions of a contract,
• an electronic document meeting the legal validity requirements. It must clearly and explicitly highlight the client's wish that their personal data, credit history, solvency, and information following value-added services be shared with BICs and their users. It must be signed by the Client and bear the mention "read and approved". A model of consent clause is presented in ANNEX B.

12.2. The BIC and Supervised Entities must ensure that their respective employees have been sufficiently trained and that required controls are in place to manage client consent.

12.3. It is up to Supervised Entities to ensure the identity of the Client during the collection of consent by implementing the necessary due diligence within the framework of AML/CFT and KYC devices.

Article 13. ACCESS RIGHTS - VERIFICATION - CORRECTION 13.1. Each Supervised Entity must have a person in charge of Data Protection or Data Protection Officer, abbreviated DPO, who (i) monitors the compliance of data processing with applicable standards, (ii) is a point of contact with the Client to answer questions concerning the processing of their data and (iii) cooperates with the Supervisory Authority.

13.2. The Client has the right to request, at any time, from the Supervised Entity the correction of their personal data and also their update. The Supervised Entity must make the necessary efforts to ensure the traceability and veracity of modified data. The Client may choose to address the BIC directly.

13.3. Solvency report requests made by the Client are addressed personally and exclusively to the BIC by any means of communication leaving a written trace. The free solvency report will be issued by the BIC once a year.

Article 14. PROCESSING OF COMPLAINTS 14.1. A Client who disputes the accuracy or completeness of any information disclosed by a BIC may file a written complaint directly to the BIC or to the Supervised Entity with which the Client has a contractual relationship. The Supervised Entity receiving a complaint must inform the BIC of the measures taken and any modifications to be made. The BIC, to resolve a complaint directly received by it, consults the Supervised Entity that sent the disputed data. The BIC and the Supervised Entity possibly consulted are required to respond as soon as possible and at the latest within 20 working days from the receipt of the complaint.

14.2. The BIC, after updating the information following the complaint, must provide the Client free of charge with an updated credit report, accompanied by a written notice informing them of their rights and the deadlines applicable for filing the complaint in accordance with Article 45 5th and 6th paragraphs of Law 2017-045 of February 15, 2018.

14.3. Clients who are not satisfied with the steps taken by the BIC after filing the complaint may resort to BFM, within 30 days following the receipt of the written report from the BIC, by making a written request according to the model in ANNEX C.

14.4. The Client's complaint form is a standard format for the submission of complaints to the Supervisory Authority, in accordance with Article 45 5th paragraph of Law No. 2017-045 of February 15, 2018. The form must be used and filled out by the Client who has a complaint to formulate regarding the accuracy or completeness of their credit information and who has already filed a complaint with the BIC.

14.5. The form duly signed and dated by the Client or their duly authorized representative must be accompanied by a certified copy of the report issued by the BIC and addressed to the Direction in charge of the supervision of BICs at Banky Foiben'i Madagasikara via mail or electronic messaging. Upon receipt of the complaint, BFM will conduct investigations and give an opportunity for the BIC to respond within a period of 20 days after receipt of the complaint. BFM may be led to reject the complaint or order the BIC to correct or complete the information in question, to limit or prohibit the publication of the disputed information and to notify the persons to whom the false or incomplete information was disclosed by the BIC. BFM will also notify the Client.

14.6. The Client or the BIC dissatisfied with the decision of BFM may freely seize the competent jurisdiction.

Article 15. OBLIGATIONS RELATING TO THE COMMUNICATION OF DATA FROM THE RISK CENTRAL TO THE BIC In the context of the communication of data from the Risk Central as provided for in Article 64 of Law No. 2017-045 of February 15, 2018, each credit institution is required to ensure that all credit operations carried out in favor of natural persons since December 4, 2018, the date of approval of the first BIC in Madagascar, have been the subject of a consent request. The obtained consent support must be available and consultable. Any establishment that has not formalized a consent request for credit operations held since the date indicated in the first paragraph of this article has a period of three (3) months from the date of entry into force of this instruction to comply and make the necessary regularizations.

TITLE VI - ADAPTATION OF SYSTEMS

Article 16. DEADLINE ALLOTTED A period of four (4) months is allotted to credit institutions for banks and financial establishments, and six (6) months for microfinance institutions, to adapt their respective systems in order to be able to periodically and obligatorily provide exhaustive and reliable data to BICs. This period runs from the date of receipt by credit institutions of the final format of the declaration required by the BIC.

TITLE VII - MISCELLANEOUS PROVISIONS

Article 17. ENTRY INTO FORCE This Instruction enters into force on the date of its publication on the website of Banky Foiben'i Madagasikara.

Antananarivo, October 02, 2019

THE GOVERNOR ALAIN H. RASOLOFONDRAIBE

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ANNEX A - MONTHLY REPORT OF THE CREDIT INFORMATION BUREAU In accordance with Article 6 of Law 2017-045 of February 15, 2017

FOR THE PERIOD OF: ____________________

1. Name of the credit bureau: ________________________________________________________________
2. Registered office: __________________________________________________________________________

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3. Indicate all other agencies: ________________________________________________________

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4. Indicate the names and addresses of all administrators, directors and senior executives: (Use the format in Annex A1)
5. List all credit data suppliers listed and in membership contract with your Credit Information Bureau (Use the format in Annex A2)

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ANNEX A - MONTHLY REPORT OF THE CREDIT INFORMATION BUREAU In accordance with Article 6 of Law 2017-045 of February 15, 2017

6. Complete the following table: (1) Solvency reports:

	Credit Information Users	MM/YYYY
		Requests		No-hits	Hit ratio
		Online	Batch
i.	Commercial Banks
ii.	MFIs
iii.	Financial Institutions
iv.	Water and Electricity Supply Companies
v.	Hire-Purchase Companies
vi.	Dealers
vii.	Large Credit Sales Stores
viii.	Telecommunication Operators
ix.	Insurance Companies
x.	Other Credit Bureaus
	TOTAL

(2) Volume of data downloaded by data suppliers and number of rejections:

	Data Suppliers	MM/YYYY
		Downloaded	Rejected
i.	Commercial Banks
ii.	MFIs
iii.	Financial Institutions
iv.	Water and Electricity Supply Companies
v.	Hire-Purchase Companies
vi.	Dealers
vii.	Large Credit Sales Stores
viii.	Telecommunication Operators
ix.	Insurance Companies
x.	Other Credit Bureaus
	TOTAL

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ANNEX A - MONTHLY REPORT OF THE CREDIT INFORMATION BUREAU In accordance with Article 6 of Law 2017-045 of February 15, 2017

(3) Volume of new credits or new contracts

	Data Suppliers	MM/YYYY
		Male		Female
		Amount	Number	Amount	Number
xi.	Commercial Banks
xii.	MFIs
xiii.	Financial Institutions
xiv.	Water and Electricity Supply Companies
xv.	Hire-Purchase Companies
xvi.	Dealers
xvii.	Large Credit Sales Stores
xviii.	Telecommunication Operators
xix.	Insurance Companies
xx.	Other Credit Bureaus
	TOTAL

(4) Totals of data in the database:

	Data Suppliers	MM/YYYY
		Volume	%
i.	Commercial Banks
ii.	MFIs
iii.	Financial Institutions
iv.	Water and Electricity Supply Companies
v.	Hire-Purchase Companies
vi.	Dealers
vii.	Large Credit Sales Stores
viii.	Telecommunication Operators
ix.	Insurance Companies
x.	Other Credit Bureaus
	TOTAL

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ANNEX A - MONTHLY REPORT OF THE CREDIT INFORMATION BUREAU In accordance with Article 6 of Law 2017-045 of February 15, 2017

(5) Status of database update:

	Data Suppliers	MM/YYYY
		Regular	At Risk	Critical
xi.	Commercial Banks
xii.	MFIs
xiii.	Financial Institutions
xiv.	Water and Electricity Supply Companies
xv.	Hire-Purchase Companies
xvi.	Dealers
xvii.	Large Credit Sales Stores
xviii.	Telecommunication Operators
xix.	Insurance Companies
xx.	Other Credit Bureaus
	TOTAL ACTIVE CONTRACTS

N.B.: For tables (1) to (5), each line must be detailed by entity

(6) Graphical representation of the historical trend, global and by type of data suppliers:

(7) Clients:

		MM/YYYY
i.	Number of reports provided to clients
ii.	Number of complaints or claims received
iii.	Number of complaints or claims still open
iv.	Number of complaints or claims beyond the period allowed by procedures
v.	Typology of complaints or claims: - on credits - on personal data - on payment history - on qualitative data
vi.	Total number of modifications made directly by suppliers with the specific submission file
vii.	Total number of modifications made by operators on request of suppliers

(8) Statistics on the delay (in days) of complaint resolution by the BIC over a period of 1 year from MM/N-1 to MM/N (9) Statistics on the types of complaints over a period of 1 year from MM/N-1 to MM/N

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ANNEX A - MONTHLY REPORT OF THE CREDIT INFORMATION BUREAU In accordance with Article 6 of Law 2017-045 of February 15, 2017

(10) Statistics on credit amounts:

Description	MM/YYYY
	Total Outstanding	New Credit
By Activity Sector NOMAC
A Agriculture, Forestry, Livestock, Fishing, Aquaculture
B Extractive Activities
C Manufacturing Activities
D Production, transport, distribution and sale of electricity, gas, steam and air conditioning
E Production, sale and distribution of water; sewerage network; waste management and remediation activities
F Construction
G Wholesale and Retail Trade, Repair of Motor Vehicles and Motorcycles
H Transport and Warehousing
I Accommodation and Food Service Activities
J Information and Communication
K Financial and Insurance Activities
L Real Estate Activities
M Professional, Scientific and Technical Activities
N Administrative and Support Service Activities
O Public Administration and Defence; Mandatory Social Security
P Education
Q Human Health and Social Work Activities
R Arts, Entertainment and Recreation
S Other Service Activities
T Activities of Private Households Employing Domestic Personnel; Undifferentiated Activities of Private Households Producing Goods and Services for Own Use
U Activities of Extraterritorial Organizations and Bodies
ii. By Credit Typology with Maturity
iii. By Credit Typology without Maturity
iv. By Lender Typology: - Bank, - MFI, - Financial Institutions, - Telco etc...)
v. By Borrower Typology - Corporate, - Individuals - SME - MSME - Micro

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ANNEX A - MONTHLY REPORT OF THE CREDIT INFORMATION BUREAU In accordance with Article 6 of Law 2017-045 of February 15, 2017

vi. By Age Bracket and Gender

	Male		Female
	Total Outstanding	New Credit	Total Outstanding	New Credit
From 18 to 30 years
From 31 to 40 years
From 41 to 50 years
From 51 to 60 years
Over 60 years

		Outstanding
vii.	Healthy / Regular Debts
viii.	Unapplied Value 1- 30D
ix.	Unapplied Value 30- 60D
x.	Unapplied Value 60- 90D
xi.	CDLC +90D

7. Indicate:

		MM/YYYY
i.	The number of clients requesting solvency reports under Article 44 of the law: - Free - Paid
ii.	The number of complaints filed
iii.	The number of corrections, supplements and deletions made under Article 45 of the law

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8. List all appeals lodged by clients against the BIC before the Court of Appeal under Article 45 of Law No. 2017-045 of February 15, 2018 and the result of all hearings: (Use the format in Annex A3)

9. List all legal actions against the BIC, brought or likely to be brought, by clients following any solvency report: (Use the format in Annex A4)

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ANNEX A - MONTHLY REPORT OF THE CREDIT INFORMATION BUREAU Pursuant to Article 6 of Law No. 2017-045 of February 15, 2017

We, ____________________ and ____________________ as two administrators of the aforementioned credit bureau, declare and confirm that the aforementioned information is accurate and complete in all material respects.

Signed: ____________________________________________________________________________________ Director's Name: __________________________________________________________________________ Date ____________________

Signed: ____________________________________________________________________________________ Director's Name: __________________________________________________________________________ Date ____________________

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ANNEX A1

Monthly Report of Credit Bureaus Pursuant to Article 6 of Law No. 2017-045 governing the activity and supervision of BICs

BIC: ____________________ FOR THE PERIOD OF: ____________________

NAMES AND ADDRESSES OF ALL ADMINISTRATORS, MANAGERS AND SENIOR EXECUTIVES OF THE CREDIT INFORMATION BUREAU (Question 4 of the monthly report)

NAME	POSITION	ADDRESS

Note: in cases where the space provided is insufficient, additional sheets must be used for details and complete information

Signature (Director) ____________________ Signature (Director) ____________________

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ANNEX A2

Monthly Report of Credit Bureaus Pursuant to Article 6 of Law No. 2017-045 governing the activity and supervision of BICs

BIC: ____________________ FOR THE PERIOD OF: ____________________

REGISTERED CREDIT DATA PROVIDERS (Question 5 of the monthly report)

NAME OF CREDIT DATA PROVIDER	DATE OF CONTRACT	ADDRESS	TELEPHONE	EMAIL ADDRESS	GENERAL MANAGER

Note: in cases where the space provided is insufficient, additional sheets must be used to provide detailed and complete information.

Signature (Director) ____________________ Signature (Director) ____________________

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ANNEX A3

Monthly Report of Credit Bureaus Pursuant to Article 6 of Law No. 2017-045 governing the activity and supervision of BICs

BIC: ____________________ FOR THE PERIOD OF: ____________________

CONSUMER APPEALS TO THE COURT OF APPEAL PURSUANT TO PARAGRAPH 45, SUBPARAGRAPH 6 OF THE LAW (Question 8 of the monthly report)

CONSUMER NAME	CIN	NATURE OF APPEAL	DATE OF APPEAL	STATUS
				IN PROGRESS	RESOLVED

Note: in cases where the space provided is insufficient, additional sheets must be used to provide detailed and complete information.

For "Resolved" when the appeal is ongoing, indicate "In Progress". If determined, indicate whether the instructions were "confirmed", "modified" or "revoked".

Signature (Director) ____________________ Signature (Director) ____________________

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ANNEX A4

Monthly Report of Credit Bureaus Pursuant to Article 6 of Law No. 2017-045 governing the activity and supervision of BICs

BIC: ____________________ FOR THE PERIOD OF: ____________________

LEGAL ACTIONS FILED OR INITIATED BY CONSUMERS ARISING FROM A CREDIT REPORT (Question 9 of the monthly report)

CONSUMER NAME	CIN	DATE OF CASE FILE (if possible)	REASON FOR ACTIONS (Actual or Potential)	ASSESSMENT OF POTENTIAL LIABILITY (MGA)	STATUS

Note: in cases where the space provided is insufficient, additional sheets must be used to provide detailed and complete information.

Signature (Director) ____________________ Signature (Director) ____________________

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ANNEX B

MODEL CONSENT CLAUSE¹

By this, I, the undersigned [full identity], give my express authorization for the processing of my personal data related to the contract [references to be inserted] after having been previously informed:

• of the nature of the data to be processed;
• of the identity of the data controller;
• of the purposes of the processing;
• of the applicable security measures;
• of the retention period;
• of my rights of access, rectification and complaint

Date and signature

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¹ To be inserted in any loan contract concluded with a natural person.

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ANNEX C

CLIENT COMPLAINT FORM (To facilitate the filing of complaints lodged in accordance with Article 45 of Law No. 2017-045 of February 15, 2018 governing the activity and supervision of Credit Information Bureaus)

A. CLIENT'S PERSONAL INFORMATION NAME: FIRST NAMES: Date of birth: CIN No., place and date of issue: ADDRESS: Telephone Home: Office: E-MAIL ADDRESS:

B. CLIENT'S REPRESENTATIVE (If you are filling out this form on behalf of someone else, please fill out this section, otherwise skip to section C). NAME: FIRST NAMES: Date of birth: CIN No., place and date of issue: ADDRESS: Telephone Home: Office: E-MAIL ADDRESS:

ARE YOU THE LEGAL REPRESENTATIVE OF THE APPLICANT? YES | NO

C. DETAILS OF THE COMPLAINT TO THE CREDIT INFORMATION BUREAU NAME OF BIC: ADDRESS OF BIC: DATE OF COMPLAINT TO THE BUREAU: (DD/MM/YYYY): MEANS OF COMPLAINT: PHYSICAL PRESENCE | WRITTEN COMPLAINT

REASON FOR THE COMPLAINT FILED WITH THE CREDIT INFORMATION BUREAU: INCOMPLETE INFORMATION | INACCURATE INFORMATION

BRIEF DESCRIPTION OF THE COMPLAINT MADE TO THE CREDIT INFORMATION BUREAU:

DATE OF RESPONSE RECEIVED FROM THE CREDIT INFORMATION BUREAU: (DD/MM/YYYY)

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RESPONSE RECEIVED FROM THE CREDIT INFORMATION BUREAU: (please attach a copy of the report received from the credit information bureau pursuant to sub-paragraph 4 of Article 45 of Law No. 2017-045 of 15/02/2018)

NATURE OF THE COMPLAINT TO THE SUPERVISORY AUTHORITY Please check the appropriate box:

• Failure of the credit information bureau to take measures to confirm, correct or complete the information
• Failure of the credit information bureau to record on the solvency report the situation after the client's complaint but before completing the steps to confirm, correct or complete the information
• Failure of the credit information bureau to provide a free solvency report for the client
• Failure of the credit information bureau to provide a written notice informing the client of their right to complain in writing to the supervisory authority within thirty days of receiving the report
• Failure of the credit information bureau to provide a copy of the corrected / completed information to all persons to whom the credit bureau had communicated incorrect / incomplete information Please provide relevant details:

SIGNATURE OF CLIENT / THEIR REPRESENTATIVE Date:

Attachments:

• Copy of CIN
• Other documents

Note: (a) In cases where the available space is insufficient, additional sheets should be used to provide detailed and complete information. (b) The duly completed and signed form, as well as a copy of the response received from the credit information bureau, should be submitted to BFM and to the following address:

DOCUMENTATION AND INFORMATION CENTERS DIRECTORATE BANKY FOIBEN'I MADAGASIKARA BP 550 -101 ANTANANARIVO MADAGASIKARA