A lender’s security document and the company’s MCA charge record should tell the same story.
CFO and company secretary
Per borrowing event
Create a debt and charge register.
Sanction and facility agreement.
The Companies Act requires prescribed charges on company property or assets to be registered. Timing, forms, additional fees and rectification routes depend on the event and current rules.
Finance should map every secured facility to the asset, lender, amount, ranking, covenant, filing and satisfaction status. Security can include present and future assets or floating interests.
Old charges left unsatisfied can block refinancing or diligence even after the loan is repaid. Satisfaction requires evidence and filing, not only a zero loan balance.
| Control | What it covers | Operating rule |
|---|---|---|
| Creation | Facility, security and charged assets are identified. | Check filing immediately after execution. |
| Modification | Amount, asset or lender terms change. | Assess fresh or modified charge filing. |
| Monitoring | Outstanding loan and MCA charge remain reconciled. | Review quarterly. |
| Satisfaction | Repayment and lender release are documented. | File and update registers. |
Treat charge filing as a financing closing condition, not a later secretarial task.
Maintain a maturity and satisfaction calendar so closed facilities do not remain on the public record.
Record the decision, owner, due date and evidence expected. A verbal explanation should become an approved working, board note, contract amendment, statutory filing or reconciliation before the item is treated as closed.
Rules, forms, thresholds and procedures can change. Use the latest official source and the actual company facts rather than copying a prior-year control or another entity’s legal position.
Classify every exception as a timing difference, data error, missing document, legal non-compliance, control-design gap or control-operating failure. This prevents management from treating fundamentally different problems as one ageing list.
The exception file should show amount or exposure, root cause, immediate correction, preventive action, owner and board-escalation threshold. Repeated low-value issues can become material when they reveal weak systems or management override.
Close the item only after the evidence agrees across source documents, books, portal data and management reporting. A screenshot or email promise is not equivalent to a completed filing, lender waiver, signed contract or reconciled ledger.
The control should operate across the full transaction population, not only the samples management expects a reviewer to inspect. For this topic, the key stages are creation, modification, monitoring, satisfaction. Each stage should identify the source system, preparer, reviewer, deadline and evidence retained.
A useful management review asks whether the legal document, accounting entry, bank movement, tax treatment and public filing describe the same event. Differences may be valid, but they should be reconciled through a dated working rather than explained from memory during audit or diligence.
Materiality should determine escalation, not whether the company keeps a record. Repeated small exceptions can show weak master data, unclear authority, system bypass or management override. Root cause and preventive action should therefore be documented separately from the immediate correction.
Corporate action should follow the correct sequence: authority, offer or decision, execution, money or asset movement, filing, statutory-register update and public-record verification. Reversing the sequence can create a transaction that is commercially agreed but legally incomplete.
Before any fundraising, restructuring or lender diligence, compare the articles, shareholders’ agreement, board records, statutory registers and MCA data. A mismatch in ownership, director authority or charge status should be escalated before closing documents are signed.