SOFOMs
Credit products, contracts, CAT, fees, default interest and CONDUSEF
Economic reality must match the contract, cover sheet, RECA, RECO, CAT, advertising, account statement and system. These tools analyze each charge by its substance and flow.
Common method of the dossier
Product review reconciles five representations of the same cost: contract, cover sheet or advertising, registration, interface and accounting calculation. Each charge is classified by its cause, timing, base and real possibility of choice; it is then tested with scenarios of normal payment, delay, reversal and termination. If technology produces a result different from the document, correcting the wording is not enough: it is determined which customers were affected, how it is remedied, and what control will prevent the divergence from recurring.
Framework of economic and contractual coherence of the product
Every product is reviewed as a flow of rights, services, money and data. For each economic concept it is identified who causes it, who receives it, what service it remunerates, how it is calculated, when it becomes enforceable and where it is communicated. Contract, cover sheet, RECO, advertising, screens, engine, accounting and account statement must assign the same nature. Renaming a charge or invoicing it through a provider does not eliminate its substance or its impact on the user.
Ordinary interest, default interest, fee, expense and the price of a service are analyzed separately. Default interest needs a base, rate, period and partial-payment rule; the CAT uses its own assumptions and does not replace the enforceable amount. A fee needs a triggering event and regulatory treatment. The inventory includes indirect charges, promoter incentives, margins and bundles. For each one the decision may be to allow, register, redesign or eliminate it, with configuration evidence and numerical examples.
Complementary services require real optionality. A SaaS plan advertised as separate must be able to be declined or canceled without the system covertly altering the availability of the credit. BillPay needs clear instructions, ownership, timing, reversals and liability. In foreign currency, the source, margin, timing and rounding are documented. The tests run through onboarding with and without the service, payment, refund, delay and termination, and show what happens when the provider fails or terminates.
Contractual classification attends to the experience, not merely the amount or the label. A uniform template may still be an adhesion contract even if it contains negotiable fields; a genuine negotiation preserves who proposed changes and which terms were modified. Corporate cards add users, processor, disputes, security and administration powers. The signed versions are compared with the authorized library and with the registered document. Electronic signature evidences that the user received exactly what they accepted.
Observations trigger remediation of the cause and the population. Correcting a clause does not resolve past charges, contracts in force or channels that retain another version. The plan quantifies customers and periods, freezes obsolete templates, tests configuration and defines refund, communication or the appropriate measure according to the facts. A subsequent sample runs through salesperson, API, system and statement. Complaints are used to detect language that is formally correct but operationally or economically confusing. The governing body receives historical risk, residual risk and evidence of effectiveness before closing the remediation.
Product change governance maintains an inventory of dependencies by concept. A rate change may affect the formula, CAT, schedule, advertising and tests; a new fee adds substance review, filing and configuration; a different provider may change data, timing, liability and experience. The change request describes the reason, population, effective date and existing routes, and does not reach production while a critical dependency remains unapproved.
Acceptance uses synthetic data and an independent financial reconciliation. The team compares quoted price, signed contract, accounting entry, charge, payment, reversal and account statement. It also runs an edge case to detect rounding, dates or unforeseen combinations. After launch, the first operations and complaints are reviewed, with the ability to stop or reverse if actual behavior contradicts the approval. This early monitoring prevents a small discrepancy from multiplying across the entire portfolio and allows any necessary remediation to be quantified quickly.
Default interest is not a fee
Define principal, rate, period, accrual, limits, application of payments and relationship with ordinary interest. Collection expenses require an event and support; a recurring fixed charge may behave as a fee.
How to put it into practice
build a numerical example; identify each charge; link service/event; compare RECO/RECA; calculate CAT; test the system; review advertising and collections. Eliminate duplication before registering.
Separate legal nature and calculation. Default interest remunerates or penalizes the breach under the contract and applicable law; a fee charges for a distinct service or event. Renaming a charge does not modify its substance. To classify it, identify trigger, base, rate or amount, period, beneficiary and actual service, and contrast contract, cover sheet, RECO, system and account statement.
The test uses a past-due installment with partial payment and another one settled during the default period. The calculation must avoid interest on improper concepts, double charging for the same delay, and accrual after the correct date. If a collection expense exists, it is analyzed independently and its service and regime are demonstrated. Product prepares numerical examples; legal validates the language; technology reproduces the results; customer service reviews the explanation to the user. The file preserves the formula, scenarios, approval, records and account-statement screenshots. Any historical difference requires defining the population, refund or correction, and communication. The conclusion does not depend on how the accounting field was labeled, but on the economic and contractual fact that generates it.
Legal basis
CONDUSEF, RECO and RECA.
CAT, default interest and late payment
Use an impact matrix by artifact and effective date. Protect existing contracts and communicate changes under the applicable regime.
Observed pattern. Differences usually appear when product calculates on a spreadsheet and technology uses different days or bases. A test case signed off by both areas reduces disputes.
How to put it into practice
version; charge; nature; formula; CAT; RECO; RECA; cover sheet; system; statement; advertising; customers; deployment; test. Keep before/after and approval.
Coherence between CAT and the consequences of delay. The CAT communicates the total annual cost under regulatory assumptions; default interest and late payment follow specific contractual and operational rules. The SOFOM must prevent advertising or the cover sheet from presenting the CAT as a contractual rate or from omitting relevant charges. A cost map relates principal, ordinary interest, default interest, fees, insurance and services with their inclusion and explanation.
Model on-time payment, short delay, partial payment, prepayment and settlement. For each scenario compare schedule, disclosed CAT, contract, engine, account statement and collections. The user must be able to distinguish the estimated cost of the credit from the exact amount enforceable on a given date. If a rate, fee or schedule is modified, materials are recalculated and records reviewed before launch. The negative test introduces a duplicate charge and confirms that reconciliation or customer service detects it. The file contains methodology, examples, versions, approvals, screens and results. Complaints about default interest feed back into the design, particularly when they reveal language that is technically correct but incomprehensible.
Closing criterion. The examples to the user include actual cutoff and payment dates to show when default interest begins. A table of opening balance, payments, interest and charges allows the final figure to be reconciled. If the engine uses a day convention different from the contract, publication is halted until it is resolved.
Legal basis
Prohibited fees checklist
Describe triggering event, service, beneficiary, cost, frequency and evidence. Compare with all the product's charges, including insurance, technology and third parties.
Observed pattern. The "what does the customer receive in return" matrix reveals charges without a differentiated service.
How to put it into practice
concept; event; service; provider; optionality; amount; duplication; prohibition; RECO; contract; system; evidence. If it cannot be explained to the user in a clear sentence, redesign it.
Review of each charge by substance. The checklist begins with a complete inventory of charges, including those invoiced by providers or included in bundles. For each one it records commercial name, triggering event, service, amount or formula, frequency, mandatory nature, recipient, registration and representation in the contract, cover sheet, advertising and system. It is then contrasted with the prohibitions and limits in force; absence from RECO is not resolved by hiding it under another concept.
A mystery-shopping test runs through quotation, acceptance, drawdown, payment, delay, cancellation and termination. Amounts charged are compared with the authorized matrix, looking for duplication, charging without service, a fee for a task inherent to the credit, or a mandatory charge presented as optional. Findings are quantified by customers and periods. Product and finance cannot approve an exception without legal review and updating of records. The file preserves the analysis, basis, approval, configuration and test cases. Before each price change, the catalog owner verifies that all channels use the same version. The checklist concludes with a decision per charge: allowed, conditioned, redesigned or eliminated.
Closing criterion. The inventory incorporates incentives paid to promoters and charges withheld by platforms, since they may be passed on to the user indirectly. Finance must show the net and contractual flow. That review helps detect a fee that does not appear as a separate line on the account statement.
Legal basis
SaaS plan, tied sale and hidden fee
Prove that users without credit can contract the SaaS, or that a real alternative exists, if that is the thesis. The screen must not preselect the charge as optional.
Observed pattern. The onboarding flow usually contradicts the optionality clause. UX evidence is part of the legal analysis.
How to put it into practice
dependency map; offer; acceptance; billing; access; cancellation; data; support; RECO/RECA; CAT; advertising. Run a test of a customer who declines the SaaS.
Real digital service or disguised cost. A SaaS plan may be legitimate if it offers a separable service, with clear price, consent, use and cancellation. It approaches a tied sale when the credit cannot be obtained without contracting it or when its cost functions as an undeclared fee. The analysis draws the commercial and economic flow: who offers, invoices, provides, uses data and receives the payment.
Compare two journeys, one with SaaS and one without it. If the alternative does not exist in practice, if the rate or priority changes without explanation, or the system activates the plan by default, the optionality is only apparent. The credit contract, service terms, cover sheet, RECO, advertising and screens must use the same classification. Cancellation and its effect on the credit in force are also tested. The file includes evidence of the service delivered, consents, usage metrics, revenue sharing, complaints and approvals. If an affiliate provides the SaaS, the mandate, data and conflict are reviewed, without assuming that corporate separation eliminates the analysis for the user. The final decision attends to substance and actual experience, not just separate contracts.
Closing criterion. Analyze what happens if the user stops paying for the SaaS but keeps the credit current. Suspension, access to data and collections must respect the promised separation. If the absence of the service prevents managing the financing, that dependency must be explained before contracting.
Legal basis
FX margin and cost to the user
If a third party executes the FX, explain its role and liability. Do not attribute to the SOFOM services it does not provide, nor conceal the total cost.
Observed pattern. Comparing the accepted quotation with the bank movement detects differences that the aggregated account statement does not show.
How to put it into practice
source/target currency; date/time; source; spread; third party; fee; acceptance; reversal; reconciliation; statement. Test weekends and cancellations.
Visible exchange rate and margin. When a credit or payment involves a different currency, the user must know the reference source, the moment of fixing, the margin, the rounding and the treatment of reversals. The FX margin may constitute an economic cost even if it is not called a fee. The price matrix separates what the SOFOM, the provider and any third party charge, and determines how it is disclosed and recorded.
Test an operation authorized on one day and settled on another, a partial refund and a cancellation. The system must apply the agreed rule and preserve the quotation used; the account statement allows the currency, rate, margin and final amount to be reconstructed. If the provider delivers an "all-inclusive" price, the SOFOM analyzes its liability and the clarity of the message. Advertising examples cannot select only favorable scenarios. The file gathers source, contract, formula, records, screens, logs and accounting reconciliation. Differences between quotation and charge are monitored, and complaints identify whether the user understood the risk of variation. A change of provider triggers a review of margin, data and documents before migrating.
Closing criterion. Control the time and time zone of the quotation, especially in channels that operate outside the source's hours. The contract defines what happens when no reference is available. The logs preserve the rate offered and accepted to resolve differences without manual reconstructions.
Legal basis
Law for the Transparency and Ordering of Financial Services.
Obtaining RECO authorization or registration
Respond to observations item by item and correct all artifacts. An explanation without a system adjustment leaves a gap.
Observed pattern. Comparative matrices make it possible to demonstrate that identical names in different products have different triggering events, or to detect that they are in fact the same charge.
How to put it into practice
concept; product; contract; cover sheet; formula; example; justification; comparables; non-duplication; file; status; effective date; test. Block parameterization until internal approval of the status.
Route for registering fees in RECO. Before offering or charging, identify the fee, service, product, amount, periodicity and channel, and confirm the applicable procedure under the regime in force. The application uses the same wording and calculation as the contract, cover sheet and system. A pending filing number must not be communicated as a completed registration or enable a charge whose condition is not yet met.
The procedure matrix controls documents, internal approval, portal user, date, requirements, response and final status. The result is then consulted and compared with sales materials. A technology test generates the charge in each channel and validates amount, tax, reversal and account statement. If the authority raises observations or rejects, product freezes the configuration and legal decides on adjustment; a parallel version is not kept in the branch or API. The file links the resolution or registration with evidence of implementation and the population affected by changes. Renewals or price modifications repeat the circuit. Thus RECO forms part of product governance and does not remain an isolated compliance task.
Closing criterion. The removal of a fee also propagates to salespeople, simulators and billing. A test after the effective date confirms that the engine stopped generating it and that prior contracts receive the defined treatment. The historical record is preserved to explain legitimate prior charges.
Legal basis
Adhesion, special amount and negotiated contract
Preserve redlines, communications and decisions. Determine which transparency obligations still apply even if the contract is not an adhesion contract.
Observed pattern. The best evidence is a matrix of the points effectively negotiable and the modifications accepted/rejected.
How to put it into practice
customer; product; amount; base version; negotiated points; lawyer; communications; redline; approval; regime; registration. Verify the UDI in force when classifying and do not publish a threshold without a date.
Classification based on the actual form of contracting. A high amount or a partial negotiation does not automatically turn an adhesion contract into a freely negotiated contract. Review who drafted the clauses, whether they are used uniformly, which elements the customer can modify and how evidence of that negotiation is kept. The registered version and the signed version must be compared clause by clause, not merely by title.
Select files of different amounts and channels. Identify variations in rate, collateral, obligations, jurisdiction and termination, and determine whether they are foreseen spaces or substantive changes. If a salesperson inserts standard annexes to avoid the adhesion regime, the practice retains the same nature. Product maintains a library of versions and authorization rules; any special clause has an approver and justification. The file integrates analysis, template, negotiated version, relevant communications and records. A test with electronic signature confirms that the user received exactly the document accepted. The conclusion considers the contracting experience and real bargaining power, avoiding using the amount as a classificatory shortcut.
Closing criterion. Document who proposed each substantive change and what consideration or risk was negotiated. A list of preconfigured choices may still be adhesion. The analysis attends to real freedom to modify terms and not merely the presence of revision marks in the file.
The committee expressly records whether the negotiation was bilateral or whether the customer only accepted predetermined options.
Legal basis
Curing a contract after observations
Run regression with examples of origination, payment, default, termination and statement. Preserve the previous version and the affected customers.
Observed pattern. A clause change may alter a screen or calculation that no one included in the scope. The impact matrix prevents that omission.
How to put it into practice
freeze version; break down the official notice; correct; check consistency; test; approve; file; keep the reference number; deploy; verify; train. Close with evidence, not with "addressed".
Remediation with population control. After observations, it is first identified whether the fault is in a clause, cover sheet, registration, calculation, advertising or execution. Documentary correction does not resolve contracts already entered into or charges processed under the previous version. The plan defines cause, products and customers affected, immediate measure, redesign and communication or remediation where applicable.
Legal prepares a matrix of observations with basis and proposed text; product confirms the economic impact; technology modifies the configuration; operations controls the migration. New enrollment, current account, delay and termination are tested to detect side effects. Versions are frozen with an effective date and the channel prevents the use of obsolete templates. If there are affected customers, amounts are reconciled and refunds, clarifications or agreements are documented without presuming a single solution. The file preserves the requirement, response, approval, records, tests and evidence of effectiveness. A subsequent sample confirms that salespeople, API and repository deliver the same contract. The closing is presented to the governing body with historical and residual risk, not just the corrected document.
Closing criterion. Communication to customers is tested with customer service and the UNE before being sent. It must explain the effect and the action required without admitting facts other than those verified. Responses and complaints are monitored to detect whether the proposed solution generated new confusion or noncompliance.
The remediation date is reconciled with the first contract that correctly used the remedied version.
Legal basis
SOFOM corporate card contract
Assign liability without improperly displacing regulatory obligations. The company's administrator must not lose controls over secondary cards.
Observed pattern. Separating the authorization, drawdown and settlement events makes it possible to identify when the credit arises and what data is reported.
How to put it into practice
roles; limit; source; authorization; acceptance; merchant; reversal; fraud; statement; fee; default interest; SIC; termination. Test a lost card, a duplicate charge and an employee's departure.
Corporate card as a system of relationships. The contract must distinguish borrower, additional users, merchant, issuer or processor, and define who is liable for spending, authorizations and disputes. It also governs the line, drawdown, cutoff and payment dates, interest, fees, blocking, replacement, data and termination. The "corporate" label does not eliminate transparency or the need to align execution with what was agreed.
The test uses an authorized purchase, an unrecognized charge, a separated employee's card, a refund and a partial payment. Each event is traced through processor, account, statement, collections and customer service. It is confirmed that per-user limits and the company administrator's powers work, and that a provider cannot change contractual rules from its platform. The economic matrix links charges with RECO and materials. The launch file contains flow, contracts with the processor, tests, security, reconciliation, scripts and approvals. An outage or termination of the third party is rehearsed to learn about data portability and dispute handling. The operation must preserve sufficient evidence without exposing credentials or card data in legal repositories.
Closing criterion. Review international-use rules, conversion and fraud blocking together with the processor. Dispute and credit timing must match between the contract and the help desk. A sample file evidences that the company received information to manage its users' cards.
The inventory of plastics and users is also reconciled when the relationship with the borrowing company ends.
Legal basis
Corporate credit, SaaS and BillPay
A modular architecture only helps if contracts and operations are also separated. Otherwise it increases regulatory and accounting confusion.
Observed pattern. A sequence diagram per use case uncovers moments in which the platform uses own funds to cover an obligation that the contract treats as credit.
How to put it into practice
case; source; instruction; acceptance; provider; fee; contract; ledger; statement; RECO/RECA; CAT; reversal; evidence. Test insufficient funds and a change of source.
Separation between credit, software and payments. A product that combines financing, SaaS and BillPay needs three clear legal and economic flows. It is identified who lends, who provides the technology, who executes payments, what instruction the customer gives and what charge remunerates each function. Presenting it on a single screen does not allow resources to be mixed or conditions to be hidden.
Model the invoice from upload to payment to the provider, including rejection, refund, application of the credit and reconciliation. Then repeat without contracting the SaaS, if it is advertised as optional. The contracts, terms, authorizations, privacy, RECO and statements must match the system. If BillPay moves funds through third parties, the mandate, accounts, timing, liability and exit are reviewed. A negative test changes the invoice after it is approved and verifies integrity controls. The file gathers diagrams, intercompany or provider contracts, pricing, tests, entries and communications. The indicators separate credit, service and payment failures so that remediation reaches the correct responsible party. The final approval explains dependencies and conditions that halt the launch.
Closing criterion. Separate account statements or sections so that the customer identifies the credit balance, the technology fee and the payment to the provider. Reconciliation follows the same breakdown. If a refund from the provider is applied to the credit, the rule and the timing must be visible and tested.
Legal basis
CONDUSEF, PUR and LGOAAC..
Next step
SVA.LAW can map flows, charges and documents, and prepare registrations and responses with operational evidence.
General information; each product and charge requires its own review.