The Norwegian Financial Supervisory Authority has published an on-site inspection report on Collectio AS, criticising significant shortcomings in the preparation of monthly client funds reconciliations and identifying a direct breach of the ICT Regulation due to the absence of an ICT operations crisis plan. The review also found failures to consolidate claims in line with supervisory guidance and instances of collecting on behalf of bankrupt clients before a formal agreement with the bankruptcy estate administrator was in place. Client funds reconciliations did not cover all client accounts and omitted required reconciliations between bank statements, accounting records and total client liability, although Collectio has since changed its routines and submitted reconciliations for May to August 2024 aligned with Circular 7/2013. On claim consolidation under Circular 1/2018, the firm identified 267 cases between 30 June 2022 and 30 June 2024 that should have been merged and has corrected them by refunding or writing down fees or restarting cases, including waiving collection fees in all affected matters. Additional findings covered incorrect limitation-date handling due to a data-entry error, payment demands that did not disclose historical default interest rates, small interest-calculation deviations of up to NOK 4 linked to the case-handling system, bank set-off of NOK 50 transaction fees on foreign deposits to a client account despite a non-set-off undertaking, and lapsed powers of attorney for operating client accounts that have now been replaced. Collectio is working on establishing an ICT crisis plan and associated routines for annual training, exercises and testing, targeted for completion early 2025, and Finanstilsynet requested confirmation once the plan is in place. The authority also asked that the letter be shared with the company’s auditor.
Norwegian Finanstilsynet 2025-01-15
Norwegian Financial Supervisory Authority inspection report on Collectio AS criticises client funds reconciliation failures and missing ICT crisis plan
The Norwegian Financial Supervisory Authority's inspection of Collectio AS revealed significant deficiencies, including breaches of the ICT Regulation due to the lack of an ICT crisis plan and issues with monthly client funds reconciliations. Collectio has since adjusted its procedures and addressed claim consolidation errors, while working on establishing an ICT crisis plan by early 2025. Finanstilsynet has requested confirmation of the plan's implementation and that the inspection letter be shared with Collectio's auditor.