Fee Overrides, Discounts & Regulatory Compliance¶
Purpose¶
This policy and procedure document governs the adjustment of statutory pawn interest, storage fees, and handling charges in Cashy-Hub, detailing the compliance rules and software validations enforced during deal extensions and redemptions.
1. Compliance Principles & Legal Framework¶
Under European pawn regulations (Austrian Gewerbeordnung / Pfandleiherverordnung and German Pfandleiherverordnung), maximum interest and storage fee rates are strictly capped by law: - Maximum Legal Rates: Operators can never override fees upward above statutory maximums. - Downward Adjustments (Discounts & Waivers): Operators may reduce or waive fees only under verified business rules (e.g., promotional campaigns, customer goodwill, verified dispute resolution, or rounding of odd cents).
2. Hard Enforcement in Cashy-Hub Software¶
Cashy-Hub enforces strict audit controls whenever an operator touches fee fields:
A. Redemption Fee Adjustments¶
During deal payback, Step 2 provides an Adjusted Fees (€) input.
[!IMPORTANT] Mandatory Note Requirement: If an operator modifies the calculated fee amount, the system strictly requires a justification in the Notes box. The Continue button remains disabled until non-empty text is entered. This justification is permanently recorded in the deal's audit history with the operator's name and timestamp for regulatory compliance.
B. Extension Fee Adjustments¶
During deal extension:
- Parent Fees Due Today (€): Accumulated fees from the expiring contract cycle must be accounted for. Reducing this value requires store manager authorization.
- Next Contract Fee Rate: The monthly rate for the renewal period is selected from approved organizational tiers (e.g. Standard 4% / month, High-Value Collateral 2.5% / month). Custom rates outside approved tiers require Administrator role.
3. Approved Override Justifications¶
When entering mandatory notes in Step 2 of the Payback modal, operators must use standardized reason codes:
| Reason Code / Category | Example Note Text | Approval Required |
|---|---|---|
| Early Redemption Grace | "Customer redeemed within 3-day grace period; second month storage fee waived per branch policy." |
Counter Operator |
| Odd Cents Rounding | "Waived € 0.42 to round total cash payback to exact € 150.00." |
Counter Operator |
| Customer Goodwill / VIP | "Approved 15% fee discount for repeat commercial client (Approved by Branch Manager M. Weber)." |
Branch Manager |
| System Outage Compensation | "Store POS offline yesterday preventing on-time redemption; late fee waived." |
Store Manager |
| Damaged Packaging Adjustment | "Storage handling fee discounted by € 10.00 due to exterior box creasing during vault handling." |
Branch Manager |
[!WARNING] Audit Flagging: All fee waivers exceeding € 50.00 are automatically highlighted on executive variance reports and audited during monthly compliance reviews.