Credit Providers contract various Service Providers and Agents in the Credit Risk and Recoveries process such as, but not limited to: Attorneys, Debt Recovery Agents, Managing Agents, Credit Bureaux, Electronic Payment System Operators, Tracing Agents, Factoring Houses and Auctioneers to sell the debt. The issue of “what” to embody in the various contracts and “how much” to charge either the Credit Provider or the Consumer remains an issue for debate - or as we prefer to say: “It’s as clear as mud”.

"The cost of credit is too high" says DTI who suggests regulations providing for caps for various products and services to be finalised within six months. The regulations would be drawn up by Trade and Industry Minister Rob Davies with Justice Minister Jeff Radebe. The cost of credit relates not only to the interest rate charged but also the monthly service fees, initiation fees, default administration charges, credit collection costs and credit insurance. DTI urged that collection costs under other laws also be capped to ensure alignment. This was where collaboration with the DOJ was needed. DTI also highlighted the need for the department to keep a watch on the fees imposed by debt counsellors, payment distribution agents and debt collectors to ensure the process was cost effective. There were many players in the sector, all of whom added their own costs. Not too sure why attorneys are left out of this section!!

Another issue raised in the DTI portfolio briefing was the selling of loan books and DTI commented that it continues to be an area of abuse towards consumers and the practice of collecting or selling debts should be prohibited and made an offence under the NCA to ensure all actions to re-activate prescribed debts be null and void.