Background
The Combined Industry Forum (CIF) requires brokers to disclose specific information to customers to improve transparency and support good customer outcomes.
For credit representatives operating under Connective’s Australian Credit Licence (ACL), use of the updated Credit Guide documents is mandatory. For ACL holders and their authorised credit representatives, Connective strongly recommends using these documents.
The information disclosed relates to settled loans from the previous financial year and must be reviewed and updated each year from 1 July.
What you must disclose to customers
Under CIF recommendations, brokers must disclose the following information in their compliance documents:
The list of residential lenders available through Connective’s panel and which of those lenders you were accredited with in the previous financial year
The number of residential lenders you settled loans with in the previous financial year
Your top six lenders and the percentage (%) of settled business with each lender in the previous financial year
Confirmation that you maintain an entertainment and hospitality register
Disclosure of any tiered servicing arrangements (also known as broker clubs)
How the Credit Guide supports CIF reporting
Connective’s updated Credit Guide template incorporates all CIF reporting requirements.
The data provided in the Credit Guide:
Is based on lenders available through Connective’s panel
Is automatically populated from Mercury, where available
Important
If you use lenders that are not on Connective’s panel, you must manually add this information to your Credit Guide. This includes lenders no longer on the panel but used during the reporting period.
If you have not been with your current broker business for a full financial year, the data provided will only cover the period you were with that business. If prior data is unavailable, include a statement confirming this in your disclosure.
Data requirement: Lenders available and accreditations held
You must disclose:
The list of Connective panel lenders for the previous financial year
Which of those lenders you held accreditation with
This information automatically appears in your Credit Guide when:
You are using the correct Credit Guide version
Your accreditations are up to date in Mercury
If you do not see this table, contact your Partnership Manager to confirm you are using the correct Credit Guide version.
Action required
Review and update your lender accreditations in Mercury
Select each lender you are currently accredited with
To update your accreditations, please read Managing-your-accreditations-in-Mercury-Nexus
Note: If you used non-panel lenders, you must manually record and disclose this information. You may also need to manually enter data for lenders who are no longer on Connective's panel but who may have been during the reporting period. You may use a table like the example below.
Data requirement: Number of lenders used
You must disclose the number of lenders you settled loans with in the previous financial year.
This data is automatically populated in the Credit Guide based on Connective panel lenders.
Note
If you settled loans with non-panel lenders or lenders no longer on Connective's panel, you must manually update this number.
Data requirement: Top six lenders and percentages
You must disclose:
Your top six lenders by settlement volume
The percentage (%) of settled loans with each lender
This information is automatically populated in the Credit Guide using settlement data.
Note
Manual updates are required if you used non-panel lenders or lenders no longer on Connective’s panel during the reporting period.
Disclosure: Entertainment and hospitality register
You must maintain an entertainment and hospitality register for all Loan Writers.
The Credit Guide includes the following disclosure:
“We hold and maintain an entertainment and hospitality register. A copy can be provided on request.”
Action required
Maintain a register for each Loan Writer
Retain records for at least three years
You must record:
All events, gifts, or hospitality valued between $100 and $350
All Loan Writers who attended the event or received the benefit
You do not need to record:
Events with at least 80% educational content
If you are unsure whether an event meets the 80% threshold, confirm this with the event organiser.
Example template:
If a client requests a copy of the register
Provide a copy covering the preceding 12 months
Supply it as soon as possible
Provide it in the format requested (email or mail)
Disclosure: Tiered servicing arrangements
Tiered servicing disclosure is only required if you have a tiered servicing arrangement with a lender.
What is a tiered servicing arrangement?
Tiered servicing arrangements (also known as broker clubs) are arrangements where a broker receives non-monetary benefits not available to all accredited brokers.
These may include:
Faster application turnaround times
Direct access to assessors
Access to upfront valuations
These arrangements do not provide customer discounts and do not entitle you to additional commission beyond what is disclosed.
If you are not part of a tiered servicing arrangement, no action is required.
How this is disclosed in the Credit Guide
The Credit Guide includes a section titled Preferential service offerings and programs.
If you hold preferential service arrangements:
The relevant lenders must be declared
Updating these lenders in the Accreditations App will automatically update your Credit Guide
Action required
Review and update your preferential service lenders in the Accreditations App
To update your preferential service lenders, click Updating-your-preferential-service-lenders Guide
Need help?
If you need help with CIF reporting, Credit Guide disclosures, or compliance requirements, contact your Compliance Support Manager or email [email protected]