Broker Record Keeping
Good record keeping can be your proof that you have made considered decisions and taken appropriate actions. Records become your protection if you are questioned or challenged. Without them, you are at risk.
Good recordkeeping can also help you to comply with a range of legislation. Keep in mind that ASIC has stated that brokers will find it very difficult to demonstrate that a proposed loan was “not unsuitable” if they have not maintained adequate records. Remember a review may occur a number of years after the initial transaction and the file must stand as a complete record. Ask yourself, if an auditor or a regulator picked up your file to review would they be able to confirm how a proposed loan was “not unsuitable” and understand the discussions held around the clients’ requirements and objectives, the risks and costs of a particular product and how the proposed transaction was “not unsuitable”.
Refer to the Oxcel Member Management Manual, for full details.
File Notes
All file notes can be captured and maintained in Infynity and are date and time stamped. We recommend that you use Infynity for all your notes/record keeping. If you enter everything in Infynity, you will have a history of all discussions and actions in the one place. It should cover but not limited to the following:
Record of when the Credit Guide was issued to all applicants and guarantors (if applicable)
How was the client sourced (referral, word of mouth, advertising etc)
Record of all phone calls and discussions with clients (initial interview, subsequent meetings and conversations)
How was client data collected (fact find, verbally, appointments etc)
Record of employment checks that have been completed and incomes verified, record of conversation kept.
Selection of Lender, products and reason why, how does it meet your clients short, medium and long term goals.
Lender serviceability and reasonable enquiry into monthly living expenses
Clarifying inconsistencies – be detailed what the inconsistency was and the outcome, and authenticity checked for fraud prevention
Fixed Rate Loan discussions –how does it meet your clients’ needs and objectives.
Fixed Rate Lock discussions – risks and costs, was it accepted or declined.
Life or General Insurance discussions – record of discussions
Record of issue and return of signed Statement of Credit Assistance (SOCA)
Post SOCA or post submission changes (use the SOCA short form as required) with supporting notes
Where applicable, notes on the issue and return of signed Credit Quote
Infynity has the functionality to post backchannel sales stage updates received from ApplyOnline when an application is submitted, approved, declined, withdrawn or settled. Record any follow ups and outcomes at these stages or in between.
Discussions with related parties like Solicitors/conveyancer, real estate agent etc
Retain all documents, emails and file notes for seven (7) years
Avoid use of WhatsApp, WeChat and other messaging application to collect documents
Compliance will conduct member file audits. If the record keeping is inadequate, you risk unsatisfactory results.
Emails
If you email from within Infynity, all email correspondence will be saved in the history of the client account. If you email outside of Infynity it is recommended that you copy the email into the notes tab within the client account or upload it as
a supporting document.
Always reconfirm important client discussions via email, so the clients have a record of the discussions or outcomes
Copy yourself in the email and retain original email with any attachments
Copy and paste client reply to emails into Infynity.
Copy and paste any Lender BDMs, Lender assessor’s emails to the client account or upload as a supporting document
Copy and paste any related party (conveyancer, real estate agent, accountant etc) emails to the client account or upload as a supporting document
Documents Sighted for Verification
Demonstrating that you have sighted and made verifications of documents is essential. Upload all supporting documents into Infynity against the client account and make notes about the verifications that you have undertaken and the outcomes.
Retain a clear copy of the documents used to verify information ie Bank statements, payslips, ID, Medicare card etc
Check documents, ask questions and make verifications with clear notes on client accountMake reasonable and scalable enquiries regarding living expenses against bank statements, with clear notes to demonstrate your actions and outcomes
Make reasonable and scalable enquiries regarding living expenses via opening banking or bank account scraping applications
Use a submission notes template, to submit with each application. If you don’t have one, create one that you can use for each submission. This will allow the assessor to use the cover notes as a reference point first before contacting you.
Your template/notes should paint the picture of who your client is and what their requirements are. It should cover but not limited to the following:
• Client background - who they are.
• Employment type and time in employment
• Savings and financial position and Funds to complete.
• Objective, Loan product selected, Loan structure, if applicable cover off on Rate Lock options for fixed loans
• Credit Status - explain any areas of concern.
• Expenses – explain any one-off expense or expenses that will reduce or cease.
• Exit strategy (if at least one applicant is 40yrs or over)
• Outline any Pricing approvals.
• Outline any discussions with Lender BDMs or Lender Assessors
Remember the Lender/assessors don’t know your client. With good notes, the assessor will be able to use the information as a reference first before asking for more information from you.
Uploading Supporting Documents
Uploading supporting documents to your client file in Infynity is a compliance requirement.
Documents should be named and separated into the appropriate folders within the Loan Documents tab as shown below:
Compliance Documents: Fact Find, Refinance Summary Report (for all refinance loans), Signed SOCA, Signed Credit Quote (if charging a fee). SOCA short form (where applicable), Signed Privacy Statement and Consent (if running a credit report).
Application Documents: All supporting documents eg. (but not limited to), Income/employment Evidence, Identification, Lender Servicing Calculator, Loan and Savings Statements, Contract of Sale, Valuations, Lender Notes etc.
Completing a Credit Search
Knowing your client’s credit score and history, will help you better match your clients to suitable lenders and products.
Majority of Lenders use auto decisioning methodology on an application based on client’s credit score.
It is also a powerful tool to help Brokers verify and assess borrower expenses and have a deeper understanding of any potential early signs of financial stress.
You can access and run a separate credit report on your clients using the right ‘’Account Options’’ tab within Infynity.
Within a client account, open up the account options menu bar
Select ‘’Run Credit Report’’
Follow the steps to generate a report, starting with step 1 to download the consent form for signing.
If you subscribe to Middle, a credit report and credit score can be an automated process if you include it as part of your subscription requirements.
If you are completing a credit report in a different way, then you must have a signed consent from your clients before proceeding with a credit report search. You can download a Privacy Statement and Consent from the “Document Libruary” and have your client sign it to provide their consent before running the credit report.
Keep good notes about the client’s credit report findings. Your notes should cover (but not limited to):
➢ Any red flags with early signs of financial stress
➢ Any paid or unpaid defaults and explanations for them
➢ Any late payments or arrears and explanations for them
➢ Any undisclosed debts – verification would be required, including guarantor loans not disclosed.
➢ Large number of enquiries and explanations for them
Be proactive and explain any issues to the Lender within your Lender notes, don’t wait for the assessor to ask for more details, as this delays the application process.
Disclaimer: This information is current as at the time of each QRG publication. It is a general information guide only.