This month we ‘go back to basics’ and discuss the regulatory requirements mandated in the NCCP Act in regard to Disclosure Documents and the provision of credit assistance.
We are regularly surprised by the confusion out there amongst Finance Brokers and the varying views as to which Disclosure Documents must be provided to the end-customer and when they must be provided.
In order to simplify things, we wanted to share the following graphic:
This example does not intend to cover all possible client interactions. For example, in some cases; several different loan submissions may be made for the same customer, and should the details vary significantly from original submission, a new Preliminary Assessment should be conducted, and an updated Credit Proposal should be provided to the customer at time of providing credit assistance.
We trust that the above helps you, although we suspect a few of you will be surprised!
Here are some further ‘myth-busting’ points for your reading pleasure:
- Yes; the Credit Guide can be combined with the Privacy Consent form, although the timing of when it must be provided does not change.
- Yes; the Privacy Consent must be signed by the client and verbal consent is not adequate before using a client’s personal information.
- Yes; the Credit Guide must include details of both the ACL holder and the authorised Credit Representative if applicable.
- No; you cannot wait and only provide the Credit Proposal at sign up as it must be provided “at the time of providing credit assistance”.
- No; the Credit Proposal does not need to be signed by the customer.
- No; you don’t need to provide a Credit Quote if you are not charging a fee to the client.
- Yes; multiple Credit Proposals need to be completed (& delivered) if multiple credit provider submissions are made.
- Yes; all Disclosure Documents are to be kept on file (electronic is fine) for 7 years post-credit assistance.
At SalesKey, we regularly engage with Finance Brokers across all asset classes and across Australia. We support many of these in their day-to-day operations, including providing a 5-day per week compliance helpdesk facility. When in doubt, these partners call the experts!