ASIC Regulations - Breach Reporting: What You Need to Know

What is required for Credit Disclosure Documents - Simplified!

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What is required for Credit Disclosure Documents - Simplified!

Credit Guide

Whether a Licensee or a Credit Representative of a Licensee, you have an obligation to give your Credit Guide to a consumer "as soon as practicable" after it is likely you will provide that consumer with credit assistance.  At QED Risk Services, we think this means as soon as you start discussing the client's personal business with them.

We also recommend that you talk the consumer through all the salient points of the Credit Guide.  This not only ensures you have covered all your regulatory objectives, but also ensures that the client knows where you are coming from and that you are an independent broker.

Information to be in the Credit Guide:

•    Licensee's name and contact details
•    Licensee's ACL no
•    Details and method for working out any fees payable by the consumer to the Licensee
•    Details of the top 6 Lenders that the Licensee has introduced consumers to
•    Details of the top 6 Lenders that a Credit Rep has introduced consumers to
•    Any commissions that the individual (employee, director or credit rep) is likely to receive
•    If the Licensee has a volume bonus arrangement with the lender, a statement that the commission payable by that lender may depend on volume written and that the commission may be volume driven
•    Any commission that a third party is likely to receive for introducing the consumer to the Licensee (including how that payment will be worked out)
•    The Licensee's IDRS and EDRS details
•    Information about preliminary assessment and reasonable enquiries
•    For Mortgage Managers, an explanation of the relationship between the mortgage manager and the lender, including any fee that the MM explicitly charges to the consumer for the service

Additionally, the Credit Guides of Credit Reps must contain the following:

•    The Credit Rep's CR number and contact details
•    Fees and charges payable directly from the consumer to the Credit Rep
•    The names of the CR's top 6 Licensees
•    Information about the CR's IDRS


Credit Quote

Unless you are charging a consumer a specific fee for your service ("fee-for-service"), you do not need to provide the consumer with a Credit Quote.

If you are not providing a Credit Quote, then either your Credit Guide must state that you do not charge fees; or your Credit Proposal Disclosure Document must state that you have not charged a fee.

Otherwise, a Credit Quote must be given.  The Credit Quote must detail:

1.    The services that are to be provided for the fee; and
2.    The maximum amount that will be charged for the fee

The Licensee must not seek to charge more than the maximum fee stated in the quote and must not seek to receive payment of the charges before the services have been provided.

Credit Proposal Disclosure Document

These docs are supposed to be provided when credit assistance is provided.  This is important.  Credit assistance is only provided when either:

1.    The Licensee suggests the consumer applies for or stays with a particular lender or product; or
2.    The Licensee assists the consumer to apply for (or increase) a particular product with a particular lender

So the proposal doc typically does not need to be given until coming back to the client with a particular suggestion.

You actually provide credit assistance at the point that you suggest a particular product with a particular lender (or suggest the client stays with their existing product or lender), or when you assist a client to apply for a particular product with a particular lender.

Normally, you will have had time to go away and consider the client's position and will be coming back to the client with a specific recommendation.  So, at that time, you should know the commissions that will be payable to you and the fees and charges applicable to the product you are recommending.

1.    What are your commissions
2.    What are the lenders different fees and charges - all of them itemised

What our clients say

"Greg & the team, Just a quick note to thank you for your on-going support and in particular most recently as I undertook an audit by ASIC. As a 'one man band' it is very confronting and having your support made this process far less stressful. I would have little hesitation in recommending your services to other ACL holders."
Joshua Swift
Swift Finance Solutions

"Having been referred to QED Risk Services by a client, I already had high expectations. In the end, the service provided by all the staff at QED Risk totally exceeded my already high expectations. I would not hesitate to recommend their services and moving forward, I personally will continue to use their services for my compliance requirements."
Alan Lishman
Auto Approve

"We requested help with formatting a borrowing power capacity calculator. We're a fan of QED's serviceability calculator and from this we've devised other calculators in our website. I like the fact I can pick up the phone and ring QED with any problem and it's solved straight away. Prompt service and all with a smile."
Frank Zelasko
Singh Finance, NSW

"Thanks so much for forwarding these (broker tools).Thanks again for your input and support...much appreciated."
H. W.
Broker, Tasmania

"I'm extremely pleased and grateful for the work that QED Risk Services provided for my ASIC Credit License. The stress, worry and paperwork were eliminated and we just had to wait on ASIC for the Approval, which was quicker than expected in the end. Thanks to all in the Team at QED!"
James Clark
Fish4Loans Pty Ltd

"We have recently upgraded our Credit Status from Credit Representative to an Australian Credit Licence holder.
We were initially hesitant to do so due to the fear of the Voluminous Paper Work, Compliance and General Bureaucracy of The Whole Process until QED were recommended to us. We have now been granted our ACL and the Whole Process conducted by QED and all their staff has been faultless. We were able to continue to concentrate on our business throughout the process and QED ensured a seamless transition from start to finish.

They have modelled our Compliance Procedures to reflect how we do business and QED will stay on board to ensure we are always compliant and meet our obligations day to day and in our Annual reporting.

I highly recommend QED just as they were highly recommended to me."
Kelvin Smith
Smith Finance Group

"CompliFast is great! As a one-man band with no business partners or support staff it keeps me accountable and gives me time to work on the business. CompliFast is a friendly reminder that you need to spend adequate time working on the business as much as in the business!"
Dynamic Loans SA

"A BIG thanks to QED for having the foresight to suggest that we pursue an ACL application despite not having an RM with the 'standard' background. We had spoken to other similar firms and had been told we wouldn't be able to apply. So you certainly earned the business with your broader understanding of what can be done."
Michael Saunders
Nexus Private Home Loans

"I cannot express my thanks enough for all the effort that QED placed into my ACL application & I am so thankful that I found your company when comparing so many different organisations that propose to offer a similar service.

My initial plan was to complete the ACL process on my own, however after countless hours of research it was proving to be a very difficult task, especially when trying to handle all of the other aspects involved in establishing a new company.

From day one I was comforted with the level of confidence, professionalism and expertise that your whole team demonstrated with this process.

QED literally made the process too easy and it was MUCH faster then advised, I am still shocked with how quickly the process was expedited.

I would have absolutely no hesitation in recommending QED Risk Services to anyone in the financial services industry.

I look forward to working with QED for ongoing compliance support & training."
Nick Ivers
Cyber Finance Pty Ltd

"You know what I like about your company? 1 - The fact that you communicate so clearly; 2 - that you are truly a leader - you had no reason to write this, yet you took it upon yourselves to provide thoughts and ideas without any need for a reward - which places you in a position of providing more relevance that virtually any other provider in the market - aggregators included; 3 - The thought that goes into your comments shows that it has been considered. Please keep up the good work"
Troy McErvale
Freedom Home Loans

"What some MFAA Broker Members had to say after a QED Compliance Presentation:

'Real-world advice that is factual and relevant to the job'
'Very practical advice'
'I'm a new broker so helped me to better understand my obligations'
'It was easy to follow and had good relevant content'
'Cut through the information to give us the necessary details succinctly'
'Clarification around the much misconstrued aspects of compliance and regulatory requirements'

Just some of the great feedback received when QED helped to share its knowledge with the broker community."
MFAA Broker Members

"Cannot thank Greg, Karen and the team at QED enough for their helpful service.
Certainly professionals in their field and highly recommended."
Richard Taylor
Australian Secure Capital

"Thanks for all of your hard work, effort and guidance.

Working with the QED team was very easy,"
M Ambrose

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