The Oxcel Consumer Lending Compliance Handbook provides comprehensive guidelines for brokers involved in consumer lending. It covers client interactions, legal obligations, and best practices from initial marketing through to loan settlement and beyond.
1. Initial Client Engagement
When meeting clients initially:
Provide your Credit Guide and Privacy Statement.
Clearly explain your role, remuneration structure, and how client complaints are managed.
Do not charge fees for residential loans without explicit Oxcel approval.
2. Client Needs Analysis
Conduct a detailed analysis of your client's financial circumstances:
Purpose of loan
Amount and preferred term
Income, employment details, and existing financial obligations
Risk tolerance and preferred loan features
Verify client affordability and suitability of recommended products
3. Loan Application Process
Step-by-Step:
Step 1: Credit Proposal
Provide the client a clear, detailed Credit Proposal.
Obtain client consent via electronic or physical signature.
Step 2: Preparing Loan Application
Use ioutsource (Salestrekker) to complete applications.
Provide clients with required documentation checklists.
Ensure client reviews and confirms the accuracy of all details before signing.
4. Application Submission & Lender Assessment
Submit the application and supporting documents promptly through ioutsource.
Delete client tax file numbers from retained documents post-submission.
Understand the types of lender approvals (Pre-approval, Conditional, and Unconditional) and clearly communicate these to clients.
Advise clients not to exchange contracts until receiving unconditional approval.
5. Client Identity Verification (AML/CTF Compliance)
Verify client identity rigorously according to AML/CTF standards.
Collect additional information for higher-risk clients (international locations, complex products).
Be vigilant for signs of fraud (fake employment details, false documentation).
6. Loan Approval & Documentation
Clearly communicate lender decisions promptly.
Review the loan offer documents thoroughly to confirm accuracy and alignment with client expectations.
Advise clients to review loan documents carefully and seek legal advice when necessary.
6. Managing Loan Approvals
Pre-approval:
Initial lender agreement, subject to valuation and additional checks.
Conditional approval:
In-principle approval with specific conditions to satisfy.
Unconditional approval:
Full approval with all conditions met; client can safely exchange contracts.
7. Settlement & Post-Settlement Procedures
Ensure proper execution and verification of all documents at settlement.
Retain comprehensive records for a minimum of 7 years post-settlement.
Regularly review client situations post-settlement to maintain quality relationships and ongoing compliance.
7. Compliance in Advertising and Communication
Maintain honesty, clarity, and compliance in advertising:
Avoid misleading claims; verify accuracy and truthfulness.
Clearly disclose fees, charges, remuneration, and comparison rates.
Adhere to regulatory standards for comparative advertising and financial product promotions.
8. Handling Client Complaints and Disputes
Clearly communicate your complaints handling process from the outset.
Maintain membership with the ASIC-approved external dispute resolution scheme (AFCA).
8. Avoiding Unsuitable Loan Recommendations
Do not recommend loans that are unsuitable or unaffordable.
Provide clear, written documentation explaining your recommendation and client's decision.
Encourage clients to seek independent advice if uncertain.
9. Professional Conduct and Penalties
Always adhere to professional and regulatory standards.
Understand penalties for breaches, including substantial financial penalties and potential loss of accreditation.
Need Compliance Assistance?
Contact Oxcel Finance:
📞 1800 010 001
📧 [email protected]
🌐 Oxcel Compliance Resources
Adhering strictly to this handbook ensures a compliant, efficient, and professional client experience.