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Best interests Duty – FAQ’s
Best interests Duty – FAQ’s
Updated over a week ago

Summary of requirements and Credit Proposal (SoRCPD)

When do I need to re-issue the SoRCPD?

The SoRCPD must be re-issued if any of the following occur:

  • Loan amount increases

  • Product changes (regardless of whether the loan amount remains the same)

  • The lender the application is lodged to changes (regardless of whether the loan amount remains the same). This is the lender changes for lender 1 to lender 2 during the course the credit assistance process.

If you have issued a SoRCPD which has been signed by the customer and then a change outlined above is made post lodgement:

  • Re-issue the SoRCPD

  • Request the change with the lender

  • Ensure that a signed copy of the SoRCPD is held by the customer to reflect the updated structure

  • Connective’s preference is to have the signed document held as soon as possible however it can be signed later (i.e. at signing of Agreements), so long as Connective can evidence the updated copy was supplied to the customer (i.e. email on file with updated document)

  • You do not need to upload a new copy of the SoRCPD to AOL

When is a new SoRCPD NOT required?

  • The lender and product remain the same however the loan amount decreases (i.e. due to valuation or another request by the customer)

  • The loan amount, lender and product remain the same however the interest rate changes between what was quoted on the SoRCPD and the final rate in the customer’s loan contract

What happens if the customer takes loan 1 with lender A as an AIP and then their circumstances change?

  • If you have completed an AIP for a customer who has selected loan 1 with lender A and three months later their situation has changed, the SoRCPD must be re-issued to reflect loan 2 with lender B

  • The Credit Guide does not need to be re-issued unless there has been a material change to your (brokers) circumstances – for example you have changed companies and there is new information (i.e. authorised representative details)

  • The preliminary assessment will need to be recompleted based on the updated situation and the product comparison of lenders who may now be more suitable for the customer.

  • In terms of documenting this for the SoRCPD, you can leverage off the existing comments if their needs, requirements, and objectives remain the same however under reason for the final choice of lender you may wish to reference the first loan and the reason why this has changed, along the lines of:

    • "Three months ago, I applied for an AIP with lender A on your behalf. Your circumstances have now changed as you have (reason – i.e. commenced a new role and have more discretionary income). Due to this, I have re-evaluated the lenders which would be the most suitable and we have discussed lenders X, Y and Z in the product comparison. You have selected lender Z for the following reasons…"

What is the difference between SoRCPD and lender credit assessment notes?

  • BID notes are focussed on the customer’s needs, requirements, objectives, and the reason for the final choice of lender

  • Credit assessment notes are focussed on the lender’s policy, how you derived the income used in the servicing calculator (i.e. PAYG / bonus income split), valuation, policy etc

  • There is no reason you cannot provide the BID notes to the lender to give the assessor the background on what the customer is trying to achieve however in itself the credit assessment notes when focussed on the above points will not meet a BID requirement if the customer’s needs, requirements, and objectives have not been documented.

Is it a legal requirement to have the SoRCPD signed?

It is not a legislated requirement, it is a Connective Credit Representative requirement.

You can read more here.

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