Central bank inspections and debtor complaints: what a CRM should record
Fines are growing, and without records there is no way to answer a complaint. Here is what a collection system should store automatically.
Following Q1 2026 inspections, the Central Bank of Uzbekistan fined 16 banks and 2 MFIs a total of 1.35 bn soums. For MFIs and pawnshops the message is clear: debt collection has to be transparent and backed by records, not by agents' word.
Four risks without a system
When collection runs on spreadsheets and personal phones, a company is exposed in four places:
- Client complaints: nothing proves what the agent said and how.
- Central bank inspections: contact history is scattered across files and messengers.
- Agent performance: violations and idle time are invisible to managers.
- Personal data: everyone can open every case, with no access rights.
What the CRM should store on its own
Manual logging doesn't work: by the end of a shift an agent forgets half of it. The system should do it without human input:
- all calls through the PBX and call recordings;
- payment promises and the outcome of every contact;
- notices and documents sent to the debtor;
- which employee worked on the case and when.
Roles and access rights
An agent should see only their own cases, and a manager the whole portfolio. This lowers the risk of data leaks and always shows who is responsible for each debtor.
The bottom line
When every contact is kept in one debtor history, a complaint can be checked in minutes, and the company has records to show at an inspection. This protects against fines and against disputes with clients.
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