Use this guide to choose suitable alternative documentation when you decide not to obtain three months of transaction account statements. It outlines what you should collect, why it matters, and how to document your verification process to meet National Consumer Credit Protection Act (NCCP) obligations.
What is flexible document collection?
You now have flexibility in how you verify a client’s income, expenses, liabilities, and dependants. Transaction accounts remain a useful option, but they are no longer mandatory. Instead, you can select documentation that best matches the client’s circumstances.
This approach supports professional judgement while ensuring you continue to meet responsible lending requirements.
Verifying income
When determining income documentation, consider:
Employment type such as salaried, contractor, or self-employed
Employment duration, especially under six months
Whether the client is new or existing
Whether you already hold reliable documents from a recent loan
If you choose not to obtain transaction accounts, the following alternative documents may help verify income:
myGov Tax Portal printout
Verbal income check with notes including date, time, and verifier’s position
Employment contract, particularly for new employment
Superannuation statement showing employer contributions
Employment letter on company letterhead
Financial Passport or Open Banking data
Existing client documents from a recent or related application
Tip: Where income is irregular or variable, use more than one source to confirm consistency.
Verifying living expenses
When verifying expenses, think about the client’s familiarity with their finances and their experience as a borrower.
First-home buyers may need guidance on typical ownership costs, including strata fees and ongoing property expenses.
Experienced investors may already have detailed oversight of their monthly outgoings.
Existing clients may have previously supplied documents to cross-reference against stated expenses.
Alternatives to transaction accounts for verifying living expenses include:
MoneySmart budget tool completed by the client
In-person review of internet banking activity, supported by notes comparing actual spending to the client’s stated budget
Existing client documents
Open Banking data
Note: If reviewing online banking in person, your notes should explain how you assessed actual spending and how it supports the client’s declared expenses.
Verifying dependants
A simple way to confirm dependants is to obtain a Medicare card showing the clients and any listed children.
Verifying liabilities
To help identify liabilities, including those not shown on credit reports, you can:
Complete an Illion credit check with the client’s consent via Digi-sign or electronic consent
Confirm any Buy Now Pay Later (BNPL) accounts directly with the client
Important: Some liabilities, including certain BNPL products, may not appear on credit reports. You must still make reasonable enquiries to identify these.
Applying the process across common scenarios
When verifying a client’s financial situation:
Select documentation that best suits the client’s profile and circumstances.
Use a combination of documents when one item does not provide enough evidence.
Record your rationale clearly in the loan file, explaining why the documents chosen satisfy verification requirements.
For examples of how to apply this in practice, see: Scenario Guidance Table
This includes common client profiles, recommended documentation, and guidance on how each item satisfies verification obligations.
Need help?
If you need help selecting appropriate documentation or ensuring your file meets compliance requirements, contact your Compliance Support Manager or email [email protected]