Towards the end of 2016, QED heard ASIC talking about what we think is their next major focus - a licensee's 'General Conduct Obligations'.
Some brokers think compliance means reviewing some of their loan files every now and then. Compliance means:
- Understanding what all your business obligations are, not just NCCP
- Having written documents - policies - that explain what your business does to meet these obligations
- Identification of the controls to ensure they are still working
- Documentation of the testing to demonstrate that it was done and what the results were
- Planning of the corrective actions that are going to fix the things you found were 'broken' and therefore get you back to full compliance again.
For the full article in MPA, http://www.mpamagazine.com.au/sections/business-strategy/opinion-how-brokers-can-stay-compliant-in-2017-231518.aspx
Director, QED Risk Services