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QED Risk Services has taken a number of distress calls recently from Credit Licensees that have felt the sudden and full brunt of ASIC’s regulatory police power. As shocked as we are at the force of ASIC’s new approach, we nevertheless can only reiterate the same message we have been emanating for the past 12 months that all Licensee businesses need a total compliance solution to cover their ACL obligations.
Despite credit industry stakeholders having recently released their “guidance” on NCCP disclosure documents, Many QED Risk Services clients have contacted us, saying they are now more confused than ever. QED Risk Services has now released its own guide, only 3 pages long, that breaks it all down and makes it simple.
QED Risk Services says the credit industry is concentrating too much on loan files and not enough on the general conduct obligations of Credit Licensees. QED has now launched an online compliance service, QED CompliFast, which will aid ACL holders in meeting their compliance obligations.
QED Risk Services Director Greg Ashe openly rebukes recent industry comments suggesting that brokers working in the investment property advice area are running foul of financial advice regulations.
Recent industry commentary has suggested that brokers need to have detailed “credit policies” or even adopt one from a Bank that you like. QED Risk Services Director Greg Ashe disagrees and encourages credit licensees to take more deliberate, but simpler actions.
Through its extensive work with mortgage brokers in 2010, QED Risk Services has identified a demand for brokers wanting to become Credit Representatives, but not with their aggregator. QED Credit Services has gained its Australian Credit Licence to adopt brokers in this position.
QED Risk Services is saddened to hear of the untimely passing of one of its most colorful clients – John R Hill in Albury
You do not have to make your total decision by 31 December. If you want to be a Licensee in 2011 but haven’t yet taken action, become a Credit Rep and then get your Licence in 2011.
Alternatively, if you want to be a Credit Rep but not of your Aggregator, QED Risk Services is set to gain its own ACL to house such brokers as Credit Reps.
Taking the middle road can lead to criticism of trying to be to much for too few. However, QED Risk Services’ experiences of dealing with the real people in the finance broking industry in 2010 has lead us to believe that we have been on the right track all along – educate on the new things, but keep it real!
6 months ago, many credit industry pundits had scoffed at the “not unsuitable” phraseology adopted by the law-makers with respect to credit. But now we are finding it to be a useful tool in navigating the “responsible lending” minefield. Find out how QED can assist your business with credit licensing and dealing with ASIC requirements.