Background
The responsible lending obligations prescribed by the National Consumer Credit Protection Act 2009 (Cth) require brokers to take reasonable steps to collect and verify borrowers’ income and expenses. As a matter of best practice, we require our Credit Representatives to evidence a systemised approach to this.
One way to assist you in meeting these obligations is to utilise a bank statement retrieval service, which assists with the collection of bank statements from their clients electronically (Bank Statement Technology). Our research indicates that the use of Bank Statement Technology saves brokers administrative time of obtaining these bank statements from their clients, creates efficiencies by assisting in the initial categorisation of income and expenses and significantly reduces the risk of potential customer loan application fraud. At the very least, use of Bank Statement Technology will assist brokers meet their responsible lending obligations and provide timely service to their clients.
As at the date of this policy, key providers of Bank Statement Technology include CashDeck (Credit Ready), illion (Bankstatements.com.au) and MOGOPLUS.
Policy
From 9 September 2019, it is mandatory that Connective’s Credit Representatives use Bank Statement Technology when requesting bank statements from their clients. Although we have an arrangement with CashDeck as described below, Credit Representatives can use any Bank Statement Technology provider in order to comply with this policy.
To comply with this policy, Credit Representatives must at least request their client provide bank statements through a Bank Statement Technology. As part of MARS, our regular file review system, we will be checking for evidence that this has occurred.
CashDeck
We have a preferred supplier arrangement with CashDeck under which we will make CashDeck’s Statement Request & Living Expense Reports tool available to our Credit Representatives. Connective has been working with CashDeck to integrate their product with Mercury.
Under this arrangement, we will cover the monthly account fee and the first five retrievals per month per individual Credit Representative – the first five retrievals are what we call ‘included retrievals’. The sixth and subsequent retrieval for the Credit Representative in the month are charged at the rate of $4 plus GST.
FAQs
What’s a retrieval?
A retrieval is a single CashDeck invitation through which a client provides data for one or more of their bank accounts. There’s more information about this here: CashDeck FAQ.
What if my clients don’t want to use CashDeck/other Bank Statement Technology?
As part of our file review process we look to see that CashDeck (or an equivalent service) was offered to the client. We understand and accept that some clients may have reservations about passing their personal details to a third party. Where a client refuses or rejects the option to use CashDeck (or equivalent) we will look to the file notes in Mercury to evidence the client’s reservations.
What about the confidentiality of clients’ banking details?
The invitations sent by CashDeck to clients expire after a few days and the banking login details permanently deleted. If clients still are concerned, they can be advised to change their internet banking passwords.
How will I be billed for CashDeck?
The ability to access CashDeck and use up to five retrievals per month is already covered by your existing monthly Credit Representative Fee.
CashDeck’s invoice for retrievals in excess of the first 5 each per Credit Representative per month will be included in your monthly Connective invoice.
What happens if there’s more than one Associate in a Partner group?
Each Credit Representative has their own quota of included retrievals. Consider an example of three Credit Representatives:
Credit Representative | Included retrievals | Retrievals Issued | Retrievals Billed |
1 | 5 | 8 | 3 |
2 | 5 | 5 | - |
3 | 5 | 3 | - |
Each month stands alone for billing and usage purposes so there is no ‘roll over’ of retrievals to later months. Per the example above, the Partner group will be billed for 3 retrievals.
What if a Credit Representative joins or leaves part way through the month?
They will still have five included retrievals for the month.
Connective brokers that do not operate under Connective’s ACL
If Connective brokers who do not operate under Connective’s ACL wish to use CashDeck, they will need to subscribe directly with CashDeck. We have negotiated a discounted rate with CashDeck for Connective brokers which you can access through the “CashDeck” tab in Mercury.
Does Connective have special arrangements with any other Bank Statement Technology providers?
No. After several months of research, we decided to partner with one Bank Statement Technology provider to ensure we received the best commercial terms. This provider was CashDeck.
More information
There’s more information on the CashDeck website here
For further information on Mercury integration click here