There are a range of laws that require lenders, brokers and introducers to have documented compliance programs in place, in addition to statutory and operational documents. 

In addition to providing all statutory and operational document templates, we also provide a range of templates that assist businesses develop their risk and compliance frameworks effectively, efficiently and comprehensively.

We offer Privacy, National Consumer Credit Protection (NCCP) Act and Anti-Money Laundering and Counter Terrorism Financing (AML/CTF) Act templates for customisation to suit the business model.

Our key documents are:

NCCP Licensing – Risk and Compliance Framework

  • Business Summary – necessary for the licence application
  • Compliance Approach
  • Dispute resolution - General
  • Conflicts of interest
  • Competency
  • Responsible lending
  • Financial Resource Adequacy
  • Technical Resource Adequacy
  • Human Resource Adequacy
  • Compensation Arrangements
  • Compliance reporting
  • Internal Dispute Resolution – Operational
  • Risk Approach

NCCP – Referrer Package

  • Referrer Appointment & Agreement
  • Referrer Register
  • Consumer Consent
  • Consumer Details
  • Telephone Contact Script
  • Referral Timelines

NCCP – Credit Representatives Package

  • Credit Representative appointment
  • Credit Representative Service Level Agreement

NCCP – Operational Policies & Procedures

  • Introducer Management
  • Credit Assessment
  • Customer Service
  • Debt Collection

Privacy – Lender Templates

  • Privacy Statement & Consent
  • Privacy Policy
  • Credit Reporting Policy
  • Privacy Compliance Program
  • Application Declines Notice

Privacy – Broker Templates

  • Privacy Statement & Consent
  • Privacy Policy
  • Privacy Compliance Program

AML/CTF Compliance Program

Internal Organisation

  • Corporate Structure
  • Designated Services
  • Designated Business Group
  • Permanent Establishments Overseas
  • AML/CTF Compliance Structure
  • AML/CTF Compliance Officer
  • Board & Senior Management Oversight
  • Summary

ML/TF Risk Identification

  • Overview
  • Product Risk Profile
  • Supplier Channels
  • Customers
  • Politically Exposed Persons

Customer Identification and Verification

  • Identification
  • Verification
  • Authentication
  • Agents of Customers

Monitoring and Reporting

  • Ongoing Customer Due diligence
  • Transaction Monitoring Program
  • Suspicious Matter Reports
  • Threshold Transaction Reports
  • International Funds Transfer
  • Originator Information in Electronic Funds Transfer Instructions

Employee Due Diligence

  • Employee Due Diligence Program
  • Disciplinary Measures

Training and Awareness

  • Compliance Program
  • Compliance Reports
  • Independent Review
  • AUSTRAC Feedback

Compliance and Audit

  • Compliance Program
  • Compliance Reports
  • Independent Review
  • AUSTRAC Feedback

Record Keeping

  • Policies and Procedures - General
  • Customer Records
  • Records
  • Systems

Appendix A:  AML/CTF Compliance Officer – Position Description