On Tuesday, ASIC released a summary of their enforcement outcomes for the January-June period of 2017.
What did ASIC identify
Of all enforcement outcomes during the first half of 2017 in Financial Services, Credit was by a wide margin the most affected field. In fact, a whopping 81% of all Financial Services enforcement results were targeted at the Credit industry. The majority of these were 'administrative remedies' - which can be anything from notification to correct practices within a business, to stripping a broker of their Credit License/Representative eligibility.
What will be looked at next
ASIC has stated that they will be paying particular attention to assessing and verifying the borrower's financial circumstances (so verifying client income, as well as investigating basic and discretionary expenses) - in particular where you are dealing with more 'at-risk' consumers such as low-income earners. Remember that EVERY case is different, but especially where expenses aren't well aligned with a reasonable benchmark you should be completing more thorough investigation of expenses.
ASIC's next areas of focus in the credit industry revolves around Responsible Lending - in particular how lenders are verifying the details of consumer loans forwarded by brokers (both to manage potential fraudulent activity, as well as to bolster the details they collect)
As you know, when pressure is put on the lenders, this gets sent on to the aggregators, who send it on to you as an ACL Holder as well as your reps. so, you absolutely want to make sure that when the aggregator wants to audit YOUR business, your files are in good working order.
Has your aggregator asked to audit your files?
Luckily, QED Complifast has a great new inbuilt feature which allows you to upload loan files for an independent review by our experienced file review team. If you're a Complifast subscriber and would like some more information on this service, or if you just want more information on QED's industry leading compliance program give us a call on 1300 [number] option 1 and we'll be happy to assist.