The latest compliance news - December 2020
Welcome to 2021! In case you missed any compliance news from last month, we've got you covered. See the December recap below.
For any compliance questions, reach out to us at email@example.com.
Referral agreements - the requirements you and the referrer must abide by, according to the NCCP Act, when referring business
Property investment referrals - the Loan Market Group has clear guidelines in relation to property investment as outlined in this policy
Flex commission - brokers must dial down flex commissions to the lowest possible rate for any consumer loans including those for asset finance and personal loans
Notes, notes, notes!
In December, we met with ASIC who reinforced the importance of providing clear and detailed notes particularly around price, i.e. why the rate is in the customer’s best interest, as well as more clearly aligning your recommendation to the customer’s goals and objectives.
Requirements and objectives: echoing the sentiment from ASIC, it’s critical that clear and detailed notes are captured in the Game Plan confirming the customer’s requirements and objectives and how the recommendation has met these. Remember, if the notes are not captured in the right section under ‘your immediate goals and objectives’ then it may impact your audit score. The key is to remember that it is no longer sufficient to simply show why a loan is not unsuitable, you have to prove why it’s in the customer’s best interests.
Consistency across ApplyOnline, servicing calculator and MyCRM: client’s personal or financial information in the Game Plan should match the serviceability calculator and ApplyOnline. If there are discrepancies, clear notes need to be left explaining why. Remember to ensure you leave clear notes in MyCRM as to how you’ve calculated your client’s income.
Uploading supporting documents: all supporting documents must be uploaded into MyCRM prior to lodging the deal into ApplyOnline
Reminder: all BID ready audits have been completed and regular audits will resume in January with each broker being audited every 6 months at a minimum.