A debt servicing ratio cap and a repayment-period limit are easy to state. Proving, months later, what income you relied on is where files fall apart.
Licensing conditions imposed on the grant or renewal of a money lender's licence introduced a debt servicing ratio cap and a repayment-period limit for low-income earners taking unsecured personal loans, along with a required risk-warning statement in advertising and, where a referee is provided, a requirement to obtain that referee's own signed written consent and attach it to the loan agreement.
The policy is not the hard part. Most operators can state their DSR ceiling. The difficulty is evidential: at review, the question is not what your policy says but what you actually relied on for a specific borrower on a specific day.
That means the income evidence itself belongs on the application record, not in an email thread. So does the DSR calculation, including its inputs, so the arithmetic can be re-run rather than re-argued. So does the repayment term as approved, distinct from the term as it stands after any later restructuring.
The referee condition is worth a separate look, because it is a design question rather than a policy one. Referees are permitted, but the referee's own signed consent has to exist before the information is used, and if the lender later learns the consent was not genuinely signed it must stop using that referee's data. An intake form that collects referee details before the consent is captured creates exactly the record a lender then cannot easily unwind.
The advertising requirement tends to be handled by marketing and forgotten by operations, which is a mistake when campaigns are produced quickly and in volume. A record of what ran, when, and carrying which statement is worth keeping alongside the lending file rather than in a separate agency folder.
The caps and definitions are promulgated by the Registrar of Money Lenders and can change. A system should let a lender configure the figures it is subject to, with effective dates, rather than hard-coding a number that quietly becomes wrong.
Covenant Desk publishes regulatory context for Hong Kong lending operations, not legal advice. Confirm how anything here applies to your licence with your own advisers.