You must provide the Summary of Requirements and Credit Proposal prior to submitting the loan to the lender. This contains important information relating to the lender/product, fees/charges and commissions you receive or will pay (e.g. referrers).
Note: Only the listed Valuation and Application fees on a selected product will be referenced in the Credit Proposal Disclosure. As per the National Consumer Credit Protection Act 2009.
A reasonable estimate of the total amount of any fees or charges that the consumer is likely to be liable to pay to any other person in relation to applying for the credit contract.
Update: Connective has included the ‘Best Interest Duty’ : Summary of your client’s requirements and objectives and the clarification of the Final Product selection.
The Summary of Requirements and Credit Proposal needs to be signed/dated by the client(s) with a copy provided to the client and a copy held on file in Nexus.
The original copy needs to be retained on file as this provides a date stamp to evidence the document was provided to your client prior to lender submission, which is the time frame required under the legislation.
If for any reason the client seeks a different lender, wishes to change the product feature(s) of the loan (i.e. switch from variable to fixed / IO to P&I etc.) or increases the loan amount, you must review your calculations (funding position/borrowing capacity and product comparison) and create a new preliminary assessment.
Once completed, reproduce the Summary of Requirements and Credit Proposal document to match the amended loan proposal and provide to your client for signing.
You must retain and record each interaction with your client so do not delete previous compliance documents. These may be requested for audit and review purposes.
The Summary of Requirements and Credit Proposal can be generated from the Disclosure Documents tab in Nexus (number 4 in the box).
Note: To generate this document, you are required to complete the Nexus - Compliance Workflow: ‘Client’s Requirements and Objectives’ and ‘Product Recommendation and Selection’ tabs.
The text you place in these two boxes is client facing, we recommend you ensure your notes are robust to ensure you can demonstrate to your clients you have clearly understood their requirements and how the final product selected meets their objectives, which is a key principle of the BID.
The document is DigiSign enabled.
To learn how to use DigiSign in Nexus, click here.
If you have any questions relating to this topic contact [email protected]