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Combined Industry Forum Progress Report:
Working towards a better mortgage broking industry for customersJuly 2018
2
About UsIn 2017 the mortgage broking industry came together to form the Combined Industry Forum (the Forum), to take action on governance and remuneration practices to achieve better customer outcomes.
The Forum consists of representatives from banks and customer owned lenders, aggregators and brokers, consumer groups (represented through CHOICE), the Australian Banking Association (ABA), the Mortgage & Finance Association of Australia (MFAA), the Finance Brokers Association of Australia (FBAA), the Customer Owned Banking Association (COBA) and the Australian Finance Industry Association (AFIA).
3
1. Executive summary 5
2. The mortgage broking industry in context 6
3. The CIF 7
3.1 Commitment of members, and membership profile 7
3.2 CIF members represent the industry 7
4. Response to ASIC Report 516 9
5. A determination to change: Industry-led reform and continuous improvement 10
6. Progress reporting 11
6.1 Reforms 1-4 11
6.2 Reforms 5-6 16
7. Other reforms – ‘Mortgage Broking Industry Code’ 17
8. The development of a ‘Customer First Duty’ 18
9. Next progress report 19
10. Appendices 20
10.1 Reporting template 20
10.2 CIF membership 23
Table of Contents
4
5
1. ASIC Report 516, Review of Mortgage broker Remuneration, Mar 17: available at https://asic.gov.au/media/4213629/rep516-published-16-3-2017-1.pdf
2. Retail banking remuneration review: available at https://www.betterbanking.net.au/wp-content/uploads/2018/01/FINAL_Rem-Review-Report.pdf
1. Executive summary
The Combined Industry Forum (CIF) is pleased to provide this progress update outlining the mortgage broking industry’s efforts towards delivering improved customer outcomes.
In November 2017, the CIF released its report responding to the proposals outlined in ASIC’s 2016 Review of Mortgage Broker Remuneration1 and also considered the third-party recommendations of the Australian Banking Association’s 2016/17 Retail Banking Remuneration Review (Sedgwick Review)2.
The CIF’s reforms were developed to:
• ensure better customer outcomes,
• preserve and promote competition and customer choice, and
• improve standards of conduct and culture in mortgage broking.
The first key milestone in implementation of these reforms has recently been reached with members reporting that their goals with respect to Reform 2 have been achieved. Reform 2 related to the move away from volume-based bonus commissions, campaign-based commissions and volume-based bonus payments. This is an important step for the mortgage broking industry towards improving customer outcomes.
CIF members have reported progress across all six reforms outlined in the final report. Three workstream groups have been established involving CIF members to further develop the remaining reforms.
The CIF is also currently considering how it can build on the ‘Good Customer Outcome’ reform outlined in its final report and extending it by incorporating a ‘conflicts priority rule’ to be known as a ‘Customer First Duty’. This duty is still under development by the CIF, but the intention is for it to be based on an easy to follow principle: putting the customer’s interests first and matching the needs of the consumer with the right home loan product and lender.
The CIF is committed to providing regular updates to regulators on the progress made by members in addressing the reforms outlined in the report.
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2. The mortgage broking industry in context
After the publication of the ASIC Report and the Sedgwick Review, the mortgage broking industry has been working towards better customer outcomes while maintaining strong stakeholder confidence. These efforts have been coordinated by the CIF and include all parts of the mortgage broking value chain, including mortgage brokers, aggregators, lenders, industry associations and consumer groups.
While this work progresses, consumers continue to benefit from the availability of the mortgage broking channel for assistance with product comparison and loan applications. A review of the industry’s complaints data and of ASIC disciplinary activities since the publication of the last CIF report in December 2017 shows that:
• mortgage broker membership of the Credit and Investments Ombudsman (CIO) service has almost tripled since 2008, so that brokers represented 91% of CIO membership. However, complaints about brokers represented just 6.1 per cent of all complaints to the CIO, with the proportion of complaints relative to CIO broker member numbers halving since 2008;
• mortgage brokers also accounted for just 1 per cent of complaints to the Financial Ombudsman Service (FOS); and
• ASIC has secured 15 convictions of brokers between 2010 and 2017, which represents 1 in 9,000 brokers per annum.3
This data provides important context to the work of the CIF. It demonstrates that consumers are not complaining at levels that indicate high levels of public concern about mortgage broker behaviour.
3. MFAA unpublished data
Consumers are not complaining at levels that
indicate high levels of public concern about mortgage
broker behaviour.
mortgage brokers also accounted for just 1 per cent of complaints to the Financial
Ombudsman Service
ASIC has secured 15 convictions of brokers
between 2010 and 2017
A review of the industry’s complaints data and of ASIC disciplinary activities since the
publication of the last CIF report in December
2017 shows that:
7
3. The CIF
3.1 Commitment of members, and membership profile
The CIF has 37 members committed to delivering reform. This represents a large cross section of the industry, particularly given the reach that members have through the value chain. Earlier this year, members contributed a membership levy to pay for legal and secretariat support of the CIF and confirmed their individual decisions to commit to achieving the objectives of the CIF, and in turn exercising their choice to implement these changes as appropriate in their businesses.
In addition to the main CIF group, there are 3 workstreams focused on addressing ASIC’s proposals. These workstreams all have at a minimum, a large and small lender, an aggregator, a broker representative, and association representatives to ensure debate is reflective of all parts of the industry value chain.
3.2 CIF members represent the industryThe CIF members capture most of the lending and aggregators and, by extension, brokers in the industry. The current CIF membership of lenders captures 87.6% of residential mortgage loans written by lenders for year to April 2018.
Aggregators represent a similar proportion in relation to their representation of the industry. It is estimated that combined, the aggregators who form part of the CIF represent more than 87% of the Australia broker market4 (based on volume of $ written).
4. MFAA, data via Corelogic unpublished – note that this data is confidential and omits one CIF member, so number is likely to be higher than the percentage provided.
8
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4. Response to ASIC Report 516
The CIF is working to implement a reform program across the mortgage broking industry to facilitate better customer outcomes through improved governance and remuneration practices.
To progress the work as quickly as possible, three workstreams have been established across all the CIF reforms:
Workstream 1 (Reforms 1 to 4)
This workstream is responsible for establishing a reporting framework to track industry progress on addressing ASIC’s proposals to:
• Change the standard commission model to reduce the risk of poor consumer outcomes
• Move away from bonus commissions and bonus payments which increase the risk of poor customer outcomes
• Move away from soft dollar benefits which increase the risk of poor customer outcomes and can undermine competition, including consideration of the following specific areas:
– Tiered servicing
– Conferences and professional development
– Entertainment and hospitality
– Lender sponsorship of aggregator events
• Have a clearer disclosure of ownership structures within the home loan market to improve competition
Workstream 2 (Reforms 5 and 6)
This workstream is responsible for progressing and measuring the industry’s response to ASIC’s proposals to:
• Establish a new public reporting regime of customer outcomes and competition in the home loan market
• Introduce an improved governance and oversight of brokers by lenders and aggregators
Workstream 3 (Code of Conduct)
This workstream is responsible for the industry reform to develop an industry code that enables enforcement, applies across the industry, and includes new participants over time.
Some aspects of the reform package – particularly those relating to ASIC’s proposal for reform of remuneration structures (Reforms 1 to 4) – are impacted by Australian competition law. The industry is committed to acting on these areas, subject to developing an appropriate structure and meeting all competition law requirements. All CIF meetings and relevant workstream meetings are held with independent legal representation present, to ensure compliance with competition laws.
The CIF is working to implement a reform program across the mortgage broking
industry to facilitate better customer outcomes
10
5. A determination to change: Industry-led reform and continuous improvement
5.1.1 Industry-led initiativeThe CIF is moving forward with integrating good customer outcomes and placing the customer at the centre of a self-regulation model that currently contemplates:
• Improved data gathering initially through self-reporting, with Key Risk Indicators (KRIs) that assist in identifying trends and issues which have the potential to become systemic.
• A comprehensive governance framework, that incorporates a mortgage industry code of conduct, Regulatory reporting, and an oversight and enforcement regime.
• A continuous improvement regime, that identifies issues and either modifies elements of the Governance structure as needed and provides feedback to organisations for remedial training and professional development.
CIF members have commenced work towards a governance and reporting structure that will build on existing self-regulation arrangements. Subject to compliance with competition laws, the CIF is also investigating how the industry’s self-regulation efforts could be monitored and assessed over time.
5.1.2 Positioning the industry in today’s environment for the future
The regulatory landscape for credit and financial services is likely to see industry change for years to come. At the time of writing, work is continuing as part of the Royal Commission into Misconduct in the Banking, Superannuation and Financial Services Industry, the ACCC Residential Mortgage Products Price Inquiry, and the Productivity Commission’s Report into Competition in the Australian Financial System. It is likely that these processes will result in further changes to the industry and the mortgage broking value chain. However, until there is more certainty as to what those changes might be, the CIF will continue to focus on the Sedgwick recommendations and ASIC proposals to build a platform for the future. In doing so, the CIF will continue to make efforts that aim at improving customer outcomes, while maintaining the commercial viability of the industry, and promoting competition.
Looking to the future, the CIF is also considering how best to work with regulators to enhance its efforts. The second half of 2018 will see more engagement as the CIF makes further progress on reform and seeks feedback from Government and regulators.
The CIF is moving forward with integrating good
customer outcomes and placing the customer at the centre of a self-regulation
model
11
6. Progress reporting
6.1 Reforms 1-4 The following outlines the progress for each of the first four recommendations. A more detailed analysis can be found at 10.1.
In response to ASIC’s proposal for changing standard commission models, CIF considered that industry participants may adopt the following remuneration principle: “To the extent that remuneration relates to loan size, remuneration should relate to the funds drawn down and utilised by a customer”. Respondents have noted that for the most part this work is well underway. The work is contingent on project management and change management particularly in relation to training and communication. There were several comments that identified that amendments to legal agreements and system changes will be necessary to finalise the implementation of this reform.
6.1.1 Remuneration and loan size
Nov 2017
Not commenced
Assessment of impact
Well progressed
Complete Dec 2018
In progress
12
Industry recognised ASIC’s expectation that there should be a move away from volume-based bonus commissions, campaign-based commissions and volume-based bonus payments paid by lenders and aggregators. Accordingly, since the commencement of the CIF, industry participants have been making individual decisions to meet ASIC’s expectations and move away from these commissions and payment structures.5
It is worth noting that the industry has undertaken highly detailed analysis of mortgage products to ensure full compliance and in doing so has identified that there are contracts that had to be amended or restructured to meet these requirements. This resulted in some delays in finalising the process for certain industry participants, but participants have reported that this process has now been completed.
6.1.2 Moving away from bonus commissions and bonus payments
Not commenced
Assessment of impact
Well progressed
Complete Dec 2017
In progress
5. Several industry participants have never paid or received these types of commissions. Further, there were some members who, for contractual reasons could not close off these payments by the December 2017 deadline. The attestation process has captured these products, which have ceased to operate with such a payment structure.
13
CIF’s proposed response to ASIC’s recommendations considered four areas:
• Tiered servicing Access to a lender or aggregator’s tiered service model should be determined using a balanced scorecard, with a maximum 30% volume component, as a proxy for productivity, as well as other criteria aligned to ‘Good Customer Outcomes’.
Access to a tiered service model to be disclosed by the broker where they are recommending a product from a particular lender.
Such programs should not entitle brokers to preferential customer discounts or to additional payments or commissions. Instead, these programs should provide preferential service which can assist customers in achieving better outcomes.
• Conferences and professional development Professional development and most education is available to all brokers to ensure ongoing competency and professional development. All conferences and professional development events must be educationally focussed (with a minimum of 80% identified education content) and aimed at continually improving customer outcomes.
Minimum education and professional development for brokers is not considered a reward but as driving a level of competency to improve customer outcomes.
Locations for conferences and professional development must be business appropriate and not likely to cause reputational harm to the industry.
In some circumstances, additional education opportunities are offered. Broker access to these additional opportunities should be based on a balanced scorecard, that does not include volume.
• Entertainment and hospitality The industry recognises the provision of high-value entertainment and hospitality may raise the risk of lender choice conflicts. The industry considers that this risk may be addressed by ensuring that lenders do not provide entertainment or hospitality to mortgage brokers which goes above the amount allowed under Fringe Benefits Tax (currently $350 per person, per event) to enable lenders and aggregators to use existing reporting for better monitoring and supervision.
Aggregators will not determine eligibility for entertainment or hospitality, wholly or partly, on the volume of loans written with any one lender or white label loan product.
For entertainment or hospitality above $100, lenders, aggregators and brokers will be required to maintain their own register of entertainment and hospitality benefits (given or received) on a rolling 12-month basis, with records kept for three years.
‘Entertainment and hospitality’ does not include professional development and education events, that have more than 80% identified education content and are offered in a business appropriate location.
This register should be kept current, advertised in the Credit Guide provided to customers and monitored by aggregators and details provided on request.
• Lenders sponsorship of aggregators events Sponsorship opportunities to an aggregator event should be made available to the aggregator’s entire lender panel. As above, the aim of any event is to increase education. Further, the ability to join an aggregator’s panel should not be contingent on the level of sponsorship provided.
6.1.3 Moving away from soft dollar benefits
Nov 2017
Not commenced
Assessment of impact
Well progressed
Complete Dec 2018
In progress
14
CIF members are demonstrating strong progress in relation to these reforms, with many noting they need to either modify existing registers or update existing policies to reflect the new requirements. Most organisations have noted that they are progressing towards achieving their intended changes in relation to soft dollar requirements.
The CIF is currently working on definitions of some terms that are proving to be difficult to find consistent definitions of, with the 80/20 rule relating to 80% of conference and professional development being required to directly relate to the work of attendees. Defining this term, which will in part be guided by existing practices industry associations for PD points will assist members to implement this reform in their business.
15
The disclosure of ownership structures has seen moderate progress. For many lenders (large and independent), there is no requirement to declare their ownership as they are the sole entity. Others have comprehensive disclosure already in place and have completed this requirement.
Remaining organisations are deciding where the disclosure would be presented in their documentation. One of CIF’s workstreams is considering this question, recognising that in some circumstances this level of disclosure may be over and above current regulatory requirements. Most respondents who will need to implement these changes have started the implementation process.
6.1.4 Clearer disclosure of ownership structures
Nov 2017
Not commenced
Assessment of impact
Well progressed
Complete Dec 2018
In progress
16
The workstreams focussing on Reforms 5 and 6 are initially focussing on a framework for data standardisation and consistent understanding of governance and public reporting requirements. The development of this framework is expected to be a driver for continuous improvement in the industry.
Work on the public reporting framework has started, with the relevant workstream initially focussing on having a clear understanding of data needs and a common approach to definition of key terms. The workstream will engage with ASIC once work is further progressed and we hope to gain specific insight on the design of the consumer disclosures. This phase of work is scheduled to be completed by the end of 2018.
In relation to Reform 6, while implementation is not expected until the end of 2020, the CIF’s aim is to make rapid progress towards building up the governance structure with a view to a staged rollout, starting this year. This is important to smooth costs for organisations when implementing the changes, and to assist them to access adequate project funding in their budget cycle.
Nov 2017
Not commenced
Assessment of impact
Well progressed
Complete Dec 2018
In progress
6.2 Reforms 5-6
17
The CIF outlined in its final report that it would investigate the development of a ‘Mortgage Broking Industry Code’ (the Code) that captures all the reforms, enables enforcement and could include new participants over time.
Workstream Three is responsible for overseeing the development of the Code and has already completed work on identifying gaps in the existing regulatory structure and existing codes of conduct. It has now shifted its focus towards drafting of the code with the intention that it will form the basis of expected behaviour in the industry, with industry associations providing overlays that outline the expectation of their members over and above the minimum.
The code development will follow the processes that would support an application for ASIC approval under Regulatory Guide 183: Approval of financial services sector codes of conduct6. The CIF is however taking a pragmatic approach and recognises the need for the Code to be developed and in place, with the option of pursuing appropriate ASIC approval at a later time or in parallel. The timing of possible ASIC approval will in part be informed by other regulatory inquiries underway.
The CIF is specifically looking at appropriate enforcement and oversight mechanisms, as well as mechanisms to enable the CIF members to respond in cases of breaches of the code.
Nov 2017
Not commenced
Assessment of impact
Well progressed
Complete Dec 2018
In progress
7. Other reforms – ‘Mortgage Broking Industry Code’
6. Note this Regulatory Guide only applies to financial services (Corporations Act). There is no equivalent for the NCCP Act.
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8. The development of a ‘Customer First Duty’
Throughout 2018, the CIF has been considering ways to build on the “Good Customer Outcomes” reforms made in the November 2017 report.
The Good Customer Outcome reflects, and adds to, the regulatory requirements that currently exist for brokers. The November 2017 response to ASIC defined ‘Good Customer Outcomes’ as an outcome where:
“ The customer has obtained a loan which is appropriate (in terms of size and structure), is affordable, applied for in a compliant manner and meets the customer’s set of objectives at the time of seeking the loan.”
It further noted:
“A ‘Good Customer Outcome’ is at the centre of what we are striving to achieve whether lender, aggregator, mortgage broker or other industry participant. The above definition sets out four key measures that need to be satisfied to determine a ‘Good Customer Outcome’:
• Appropriate size and structure of the loan,
• Meeting the customer’s stated requirements and objectives,
• Affordability for the customer, and
• Applied for in a compliant manner (meeting all responsible lending requirements).”
The CIF has agreed in principle to extend this requirement to also incorporate a ‘conflicts priority rule’ as a ’Customer First Duty’. The ‘conflict priority rule’ could be formulated as a requirement for the customer’s interests to be placed above the providers, or those of their organisation, based on the information reasonably known to the provider, at the time of providing the service. The effect of this approach would be a requirement to place the customer’s interests first.
The combination of the good customer outcome definition and a customer first duty allows both an easy to follow principle – put the customer’s interests first - and structure to follow for brokers when assessing loan suitability. Further governance metrics can be built around this concept for monitoring and oversight.
In forming a common position for the CIF, it is evident that the development and application of a customer duty is multi-faceted and complex, and there may be unknown impacts. These include the potential for limiting access to credit, and a disproportionate impact on smaller and regional lenders if lender panels require rationalisation.
While the CIF has not settled on a final position, it has, agreed on the following key principles that should underpin any reform:
• placing the customer first, and having ‘good’ consumer outcomes at the centre of its approach
• fit-for-purpose for the mortgage broking industry, considering the nature of services provided, the form of conflicts of interests inherent to the industry, the current evidence of risks to customer outcomes, and considering the current regulatory framework
• promoting competition, and ensuring that no part of the value chain is unfairly disadvantaged
• all parts of the value chain will have a role to play to support the implementation and monitoring the customer duty
• providing transparency for all participants, and
• promoting simple, achievable solutions.
Finally, the CIF is aware that there is merit in moving a customer first principle from an implicit expectation, to an explicit statement that a customer and mortgage advice provider can easily understand.
19
9. Next progress report
The CIF is committed to keeping Treasury and Regulators informed about industry progress in responding to ASIC Report 516.
In the initial report, the CIF committed to reporting on the following milestones:
In addition to the above the CIF has also started work towards developing a Mortgage Broking Industry Code and is aiming to have a version in place by end 2018.
The CIF intends to provide Treasury with an update on progress in early December 2018. A finalisation report of member’s implementation of Reforms 1-5 which are scheduled to be in place by 31 December 2018 will be delivered in first quarter 2019. The implementation of actions contained in proposed Reform 6 are scheduled to be implemented on a staged basis through to the end of 2020, with progress reporting continuing as required, on a six-monthly cycle.
ASIC’s proposal Proposed implementation
Changes to the standard commission model End of 2018
Move away from bonus commissions and bonus payments End of 2017
Moving away from soft dollar benefits End of 2018
Clearer disclosure of ownership structures End of 2018
Establishing a new reporting regime End of 2018
Improved governance and oversight of brokers End of 2020
December 2018 Progress Report
March 2019 Reforms 1-5 Final Report
Progress Reporting on Reform 6 through
to 2020
Timeline
June 2018 Progress Report
20
10. A
pp
end
ices
10.1
Rep
ort
ing
tem
pla
teR
ecom
men
datio
ns 1
-4 re
mun
erat
ion
and
paym
ents
Rec
om
men
dat
ion
Hav
e no
t co
mm
ence
d a
n as
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men
t o
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e im
pac
t
So
me
pro
gre
ss
mad
e in
im
ple
men
ting
the
re
qui
rem
ents
Wel
l pro
gre
ssed
in
imp
lem
entin
g
the
req
uire
men
ts
Imp
lem
enta
tion
com
ple
te
Rec
om
men
dat
ion
not
app
licab
le
(bas
ed o
n th
e ty
pe
of
bus
ines
s, b
roke
r, ag
gre
gat
or)
.
Wha
t ac
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es d
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The
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an r
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cha
nges
to
po
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s an
d p
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dur
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com
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and
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in
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initi
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pro
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des
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you
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tand
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on
mo
del
Ado
pt th
e re
mun
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prin
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e to
the
exte
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that
rem
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s to
loan
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e fu
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draw
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and
utilis
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cust
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and
net
of
offs
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Mo
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Indi
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ecis
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base
d bo
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ign-
base
d co
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to
brok
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Rem
oval
of d
isco
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greg
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hite
labe
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spec
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loan
s)
Mo
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ay f
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so
ft d
olla
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enefi
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Tier
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ervi
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• A
cces
s to
a L
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ggre
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ered
se
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e m
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sho
uld
be d
eter
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sing
a
bala
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sco
reca
rd, w
ith a
max
imum
30
% v
olum
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, as
a pr
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for
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s w
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‘Goo
d C
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Out
com
es’
• A
cces
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a ti
ered
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ill be
dis
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brok
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they
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com
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a p
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at
part
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• Ti
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s do
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to p
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ial c
usto
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dis
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or to
add
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al p
aym
ents
or c
omm
issi
ons.
21
Rec
om
men
dat
ion
Hav
e no
t co
mm
ence
d a
n as
sess
men
t o
f th
e im
pac
t
So
me
pro
gre
ss
mad
e in
im
ple
men
ting
the
re
qui
rem
ents
Wel
l pro
gre
ssed
in
imp
lem
entin
g
the
req
uire
men
ts
Imp
lem
enta
tion
com
ple
te
Rec
om
men
dat
ion
not
app
licab
le
(bas
ed o
n th
e ty
pe
of
bus
ines
s, b
roke
r, ag
gre
gat
or)
.
Wha
t ac
tiviti
es d
o y
ou
pla
n to
do
in t
he n
ext
3 m
ont
hs?
The
se c
an r
elat
e to
cha
nges
to
po
licie
s an
d p
roce
dur
es,
com
mun
icat
ion
and
tra
inin
g
and
cul
tura
l cha
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and
in
clud
e m
atte
rs r
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to
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is in
itiat
ive
as w
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s o
ther
al
igne
d in
itiat
ives
out
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e th
e sc
op
e o
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is in
itiat
ive.
Hav
e th
ere
bee
n an
y ne
w
sig
nific
ant
imp
lem
enta
tion
risk
s id
entifi
ed s
ince
su
bm
issi
on
of
the
last
p
rog
ress
rep
ort
up
dat
e o
r ch
ang
es t
o p
revi
ous
ly
iden
tified
imp
lem
enta
tion
risk
s in
ach
ievi
ng t
he o
bje
ctiv
e/o
utco
me
of
the
initi
ativ
e?
Ple
ase
pro
vid
e d
etai
ls a
nd
des
crib
e w
hat
you
are
do
ing
to
man
age
thes
e ri
sks.
Co
nfer
ence
s an
d p
rofe
ssio
nal d
evel
op
men
t
• A
ll co
nfer
ence
s an
d pr
ofes
sion
al
deve
lopm
ent e
vent
s m
ust b
e ed
ucat
iona
lly
focu
ssed
(with
a m
inim
um o
f 80%
id
entifi
ed e
duca
tion
cont
ent)
and
aim
ed a
t co
ntin
ually
impr
ovin
g cu
stom
er o
utco
mes
• A
ll lo
catio
ns fo
r co
nfer
ence
s an
d pr
ofes
sion
al d
evel
opm
ent m
ust b
e bu
sine
ss a
ppro
pria
te a
nd n
ot li
kely
to
caus
e re
puta
tiona
l har
m to
the
indu
stry
• A
ny a
dditi
onal
edu
catio
nal o
ppor
tuni
ties
bein
g of
fere
d to
bro
kers
are
bas
ed o
n a
bala
nced
sco
reca
rd, w
hich
doe
s no
t in
clud
e lo
an v
olum
e
Ent
erta
inm
ent
and
ho
spita
lity
• N
o en
tert
ainm
ent o
r ho
spita
lity
to b
e pr
ovid
ed b
y le
nder
s to
bro
kers
ove
r th
e va
lue
of $
350
per
pers
on, p
er e
vent
and
no
t bas
ed o
n lo
an v
olum
e
• A
ggre
gato
rs to
not
det
erm
ine
elig
ibilit
y fo
r en
tert
ainm
ent o
r ho
spita
lity,
who
lly o
r pa
rtly,
on
the
volu
me
of lo
ans
writ
ten
with
an
y on
e le
nder
or
whi
te la
bel l
oan
prod
uct
• A
ll le
nder
s, a
ggre
gato
rs a
nd b
roke
rs to
m
aint
ain
a re
gist
er o
f ent
erta
inm
ent a
nd
hosp
italit
y be
nefit
s (g
iven
or
rece
ived
) on
a ro
lling
12-m
onth
bas
is w
ith re
cord
s re
tain
ed fo
r at
leas
t 3 y
ears
• E
nsur
e re
gist
er is
kep
t cur
rent
and
ad
vert
ised
in th
e C
redi
t Gui
de p
rovi
ded
to
cust
omer
s an
d m
onito
red
by a
ggre
gato
rs
and
deta
ils p
rovi
ded
on re
ques
t
22
Rec
om
men
dat
ion
Hav
e no
t co
mm
ence
d a
n as
sess
men
t o
f th
e im
pac
t
So
me
pro
gre
ss
mad
e in
im
ple
men
ting
the
re
qui
rem
ents
Wel
l pro
gre
ssed
in
imp
lem
entin
g
the
req
uire
men
ts
Imp
lem
enta
tion
com
ple
te
Rec
om
men
dat
ion
not
app
licab
le
(bas
ed o
n th
e ty
pe
of
bus
ines
s, b
roke
r, ag
gre
gat
or)
.
Wha
t ac
tiviti
es d
o y
ou
pla
n to
do
in t
he n
ext
3 m
ont
hs?
The
se c
an r
elat
e to
cha
nges
to
po
licie
s an
d p
roce
dur
es,
com
mun
icat
ion
and
tra
inin
g
and
cul
tura
l cha
nge
and
in
clud
e m
atte
rs r
elat
ing
to
th
is in
itiat
ive
as w
ell a
s o
ther
al
igne
d in
itiat
ives
out
sid
e th
e sc
op
e o
f th
is in
itiat
ive.
Hav
e th
ere
bee
n an
y ne
w
sig
nific
ant
imp
lem
enta
tion
risk
s id
entifi
ed s
ince
su
bm
issi
on
of
the
last
p
rog
ress
rep
ort
up
dat
e o
r ch
ang
es t
o p
revi
ous
ly
iden
tified
imp
lem
enta
tion
risk
s in
ach
ievi
ng t
he o
bje
ctiv
e/o
utco
me
of
the
initi
ativ
e?
Ple
ase
pro
vid
e d
etai
ls a
nd
des
crib
e w
hat
you
are
do
ing
to
man
age
thes
e ri
sks.
Lend
er s
po
nso
rshi
ps
of
agg
reg
ato
rs a
nd
even
ts
• P
rovi
de a
ny s
pons
orsh
ip o
ppor
tuni
ties
to a
n ag
greg
ator
eve
nt is
mad
e av
aila
ble
to e
ntire
lend
er p
anel
and
the
aim
of a
ny
even
t is
to in
crea
se e
duca
tion
• E
nsur
e th
e ab
ility
to jo
in a
n ag
greg
ator
’s
pane
l is
not c
ontin
gent
on
the
leve
l of
spon
sors
hip
prov
ided
Cle
arer
dis
clo
sure
of
ow
ners
hip
str
uctu
res
Dis
clos
e ow
ners
hip
stru
ctur
e if
of ‘S
igni
fican
t In
fluen
ce’ a
s gu
ided
by
AA
SB
128
– d
iscl
osur
e re
quire
d w
here
for
exam
ple:
• O
wne
rshi
p is
20%
or
grea
ter;
or
• W
here
ow
ners
hip
is le
ss th
an 2
0%, a
bo
ard
seat
is h
eld,
or
a w
hite
labe
l pro
duct
is
offe
red
by a
sub
stan
tial s
hare
hold
er.
(Nee
d to
ens
ure
this
app
lies
to le
nder
ow
ned
brok
er b
usin
esse
s)
Ens
ure
disc
losu
re o
blig
atio
ns e
xten
d be
yond
m
ortg
age
brok
ers
and
appl
ies
to a
ll pl
ayer
s in
ho
me
loan
dis
trib
utio
n ch
ain,
incl
udin
g le
nder
s an
d ag
greg
ator
s
23
10.2 CIF Membership
Organisation Type
ABA Industry Association
AFIA Industry Association
AMP Bank Lender
Astute Aggregator
Aussie Home Loans Aggregator
Australia and New Zealand Bank (ANZ)
Lender
Australian Finance Group (AFG) Aggregator
Bank Of Queensland/Virgin Money Lender
BeckMitch Consulting Broker
Bendigo and Adelaide Bank Lender
Choice Aggregation Services Aggregator
CHOICE Consumer Advocacy Group Consumer group
COBA Industry Association
Commonwealth Bank of Australia Lender
Connective Aggregator
Credit Union Australia (CUA) Lender
Divitis Finance Broker
FAST Group Aggregator
FBAA Industry Association
Foster Finance Broker
Organisation Type
Gilbert + Tobin Lawyers Ind. Legal Advisors
Heritage Bank Lender
ING Lender
Lendi Broker
Liberty Financial Aggregator
Loan Market Aggregator
ME Bank Lender
MFAA Industry Association
Mortgage Choice Aggregator
National Australia Bank Lender
NMB Aggregator
PLAN Australia Aggregator
Smartline Aggregator
SmartMove Broker
Suncorp Lender
Tailored Lending Broker
Vow/YBR Aggregator
Westpac Lender
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