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Policy Statement & Submission

2004/10/11

Commercial Credit Reference Agency (CCRA)

7 October 2004
Our Ref: SME/CC/179


Mr Raymond Chan
Head (Banking Development)
Banking Development Department
Hong Kong Monetary Authority
55/F Two International Finance Centre
8 Finance Street, Hong Kong


Dear Raymond

Thank you for taking time from your busy schedule to share the operation of the Commercial Credit Reference Agency (CCRA) with members of the Chamber SME Committee. The participation by Ms Jean Chan, Chairman of the HKMA Working Group on CCRA and Ms Maisie Chan of Dun & Bradstreet (HK) Ltd has helped to clarify some of the concerns of members. From the discussion at the meeting, we would like to draw your attention to the following.

1) It is hoped that with the help of CCRA, renewal and set up fees on loans could be lowered.

2) Our members were of the view that it should be the responsibility of the financial institutions to notify the concerned SME prior to the upload of information to the database. It would not be unreasonable for SMEs to request for an initial report of information pertaining to their company. Any discrepancy could be reported to D&B within a specified period of time. SMEs are concerned if they would be compensated for loss resulting from incorrect data of the CCRA.

3) SMEs should be alerted on any movement of their record (such as usage or amendment on information) through a simple email message. The SMEs concerned could then decide whether to request for a full report. A modest retainer's fee could be levied, if needed.

4) The use of data, both inside and outside of Hong Kong by D&B and money lenders should be closely monitored.

5) As banks are the primary party to benefit from CCRA in having access to credit information of their clients, they should bear the cost of the operation of CCRA. Conversely, any measure to improve the transparency of banks for SMEs would be welcomed, for example, some kind of database to reflect banks' performance, complaints received, etc.

Yours sincerely


Emil Yu
Chairman
Small and Medium Enterprises Committee

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