The last couple of years have seen huge changes in the regulatory landscape for our members. With a busy business to run and so many moving parts to keep track of, our ACL holders may struggle to feel in control of their compliance obligations.
Connective has developed an offering to help give you the peace of mind that comes from knowing your loan files are up to standard with minimal investment of your time and resources. The ACL Compliance Program offers you an independent review of your client files stored within Mercury Nexus.
File audits
We will review your residential loan files and provide feedback. The number of files we review will be up to you but should be commensurate with the scale of your business. Connective will follow up remediation of these files with your loan writers, giving them 7 days to action or acknowledge. With Connective’s support, you will be reassured that loan writers within your business are complying with the law and quickly identify the need for training or further development within your team. This also provides a useful third-party perspective for ACL holders who have been auditing their own files, as it can be difficult to remain objective when looking at your own work.
How much does it cost?
3 files (1 loan writer) | $270 plus GST |
5 files (1 loan writer) | $425 plus GST |
6 files (up to 2 loan writers) | $480 plus GST |
9 files (up to 3 loan writers) | $675 plus GST |
12 files (up to 4 loan writers) | $840 plus GST |
15 files (up to 5 loan writers) | $975 plus GST |
More file reviews needed? | Speak to Connective |
This service is pay-as-you-go, no lock-in contracts!
The prerequisites for the above offering are:
You will need to use Mercury Nexus as your CRM to enable Connective to audit your files. Within an opportunity in Mercury Nexus, you will need to use and complete:
Connective’s templated ACL compliance disclosure documents.
Compliance centre to assist in capturing your Best Interest Duty requirements.
Refer to the program's Terms and Conditions below.
ACL Compliance Program Q & A
I have 5 loan writers within the business, but only 2 do residential mortgages. Can they all sign up?
This compliance program is targeted at loan writers who provide credit assistance service for residential lending. Loan file audits will be conducted on consumer residential lending only.
I have a few direct lender accreditations, but most of my deals are submitted through AOL. Will you still audit these files?
Connective will audit loan files that have been completed in Mercury and submitted through AOL.
Do we have to complete the corrective actions?
No, however, it is highly recommended as corrective actions are in line with base-level legislation. Under this program, the onus remains with the director of the license or the responsible manager to update the policies or remediate the loan files.
Will the Connective Agreement holder have to sign another Agreement for this program?
No, just ensure that you have read and understood the terms and conditions that can be found below.
How do I pay for the ACL compliance program?
The payment will be charged to the Connective Agreement holder for each file review requested. Connective will send you an invoice that will need to be paid prior to the audit commencing,
I use Connective’s compliance documents but have added some additional commentary. Is this still ok?
The current templates Connective provides cover the mandatory requirements outlined under the NCCP. As the ACL holder, it is up to you if you want to deviate from the templates provided; however, you are responsible for ensuring they remain compliant.
ACL Compliance Program- Terms and Conditions
This sets out the terms and conditions for Connective members who want to take part in the ACL Compliance Program. This Program is a pay-as-you-go service. The fee payable is dependent on the number of files Connective would review.
By requesting Connective to audit your files, you:
must use Mercury as your CRM and store all correspondence and compliance documentation relating to your client-loan file within an Opportunity in Mercury
must use Connective compliance document templates.
must use the Compliance Centre in Mercury to capture your Best Interests Duty requirements.
acknowledge that the files reviewed are limited to consumer residential loans that are submitted through Apply Online (AOL).
acknowledge that this ACL Compliance Program service is a targeted review focused on whether a loan file meets responsible lending and best interests duty obligations and is based on the information stored in your Mercury account. The Service does not absolve you of your responsibility for meeting your general conduct obligations or any other applicable legislation. Our service may identify corrective actions and recommendations to assist you in meeting your general conduct obligations. The ACL holder and full member retains overall responsibility for all actions (or inaction) of their loan writers and themselves.
acknowledge it is your responsibility to ensure you take a copy of the file review feedback once it is provided. In the future, if your Mercury account is closed, you will not be able to access these results.
acknowledge and agree that Connective is not responsible for any loss or liability that you or your directors, employees, associates, contractors, or customers may suffer as a result of using this Service.
acknowledge the terms and conditions are subject to change at Connectives discretion.
agree to the terms and conditions of this Service.
How do I sign up?
If you would like to sign up or have any questions, send an email to the Compliance Team at [email protected]