Knowledge Base

Yes, you can apply for an Australian Credit Licence that allows you to do both - lend money (credit provider) and be a broker (credit assistance provider).

Note - it's a more complicated application and the assessment by ASIC typically takes up to several months longer to finish.

Yes and no.

You can offer both services; however this will likely mean that your asset finance applications will be subject to Best Interests Duty (BID) which adds a significant layer of regulation to your activities.

Yes. Small Amount Credit Contracts (SACC) and Medium Amount Credit Contracts (MACC) are what used to be referred to as 'payday loans'. These are regulated under the NCCP Act and require you to be licenced as a lender.

Yes. Credit Repair services are covered by the NCCP Act and as such you will need an ACL to do this.

Yes. You will need an ACL if you want to be a lender.

Individual ACLs are subject to different conditions are are based on what tell ASIC you require the licence for at the application stage. You can apply for a licence for:

• Lending • Mortgage Broking • Asset Finance Broking • A combination of lending and Broking

Under the NCCP Act, 'credit assistance' is essentially when you suggest that a consumer apply for a particular credit product with a particular lender, or help them apply for it. In simple terms: recommending a specific loan/lender or helping the customer obtain that loan.

An Australian Credit Licence (ACL) authorises credit activities under the NCCP Act, while an Australian Financial Services Licence (AFSL) authorises the provision of financial services under the Corporations Act 2001 - such as insurance products.

Some businesses need both — for example, a firm that brokers credit and also provides general advice about financial products. The two licences have separate application processes, responsible managers and compliance frameworks, though some arrangements can be shared.

The NCCP Act sets out the ongoing obligations for a licensee, including:

• Internal Dispute Resolution (IDR) procedures that meet ASIC standards
• External Dispute Resolution (EDR) membership (AFCA)
• Professional indemnity insurance covering the authorised activities
• Responsible lending obligations when providing or broking credit
• Annual compliance reporting and fee payments to ASIC
• Maintaining competent Responsible Managers and notifying ASIC of key changes
• Acting Efficiently, Honestly and Fairly

No, but the conditions on the licence will be different.

You will need to specify if you are seeking to be a mortgage broker or an asset finance broker in your application.

ASIC charges application fees that vary by the authorisations sought. As a guide:

• Limited authorisation (e.g. broking only): a lower tier fee
• Full authorisation (providing and broking credit): a higher tier fee

In addition to the application fee, licensees pay an annual levy and may incur costs for compliance setup, EDR membership, professional indemnity insurance, and legal advice.

Let us know. Cornerstone Compliance can discuss additional services. For questions about services or pricing, contact the team at hello@cornerstonecompliance.com.au or on 0435 562 801 and they will promptly reply.

The 'fit and proper' test applies to the licensee entity and its key individuals (directors, secretaries, senior managers and Responsible Managers). ASIC considers:

• Whether the person has been banned or disqualified from providing financial services or credit
• Bankruptcy history (for individuals)
• Criminal convictions, especially involving fraud or dishonesty
• Whether the person has breached financial services or credit laws

A person who is not fit and proper cannot be in a position of influence over the licensee.

There is no fixed number — it depends on the scale, complexity and nature of your business. A single RM may be enough for a small broking operation, while larger or multi-activity licensees typically require several.

ASIC assesses whether the nominated RMs collectively cover all authorised activities and can adequately supervise the business.

ASIC's published service standard is to assess a complete application within 150 days, but straightforward applications can be decided sooner. The process takes longer when:

• The application is incomplete or missing supporting documents
• ASIC requests further information about Responsible Managers or compliance arrangements
• The applicant has a complex corporate structure

Prepare thoroughly to avoid the most common cause of delay — ASIC's requests for further information.

A Responsible Manager (RM) is an individual nominated by the licensee to oversee the day-to-day provision of credit activities and ensure compliance.

ASIC requires RMs to have the skills, knowledge and experience relevant to the authorised activities. This is typically demonstrated through qualifications, a minimum number of years in the industry, and completion of relevant training.

ASIC must be satisfied on several core matters before ASIC will grant a licence:

1. Adequate resourcing — financial, technological and human resources to carry on the business.
2. Competent Responsible Managers — at least one person nominated to oversee the business.
3. Fit and proper persons — the licensee and its officers must meet character standards.
4. Compliance arrangements — compliance frameworks, policies and processes.
5. No disqualifications — no banned or disqualified persons in key roles.

You need an ACL if you engage in 'credit activities', which include:

• Providing credit to a debtor under a consumer credit contract or consumer lease
• Broking credit by assisting a debtor to apply for consumer credit
• Leasing goods to a consumer under a consumer lease

The activity must relate to credit provided for personal, domestic or household purposes, or for investment in residential property.

An Australian Credit Licence (ACL) is a licence issued by the Australian Securities and Investments Commission (ASIC) that authorises a person or entity to engage in credit activities regulated under the National Consumer Credit Protection Act 2009 (NCCP Act).

If you provide 'credit assistance' to consumers (such as a broker), you generally must hold an ACL, be an employee of an ACL holder, or be an authorised representative (ACR) of a licensee.

Frame the ACL application as a development pathway, not an exit. Many aggregators support this transition openly: it strengthens the group's collective compliance culture, and the newly licensed broker frequently remains within your aggregator network — now as a fellow licensee rather than a representative.

Yes. If you are notified of a complaint, Cornerstone assists with drafting your AFCA responses.

Not every ACR should or can apply, and an unsuccessful or poorly prepared application wastes everyone's time. The good candidates are the ones who can already demonstrate:

• They have competent responsible managers
• Fit and proper people
• Compliance frameworks
• Professional indemnity insurance

Yes. Cornerstone provides annual compliance training, delivered live either on site or remotely.

The pitch to your representatives is genuinely attractive, and it should be framed as mutual:

• Autonomy and flexibility — their own licence lets them authorise their own staff and ACRs, choose their own lenders and aggregators, and build a business without depending on a single authorisation structure.
• Commercial upside — an individually licensed business can negotiate aggregator arrangements on its own terms, and is often viewed more favourably by lender panels and acquirers.
• Professional standing — holding an ACL signals maturity, compliance capability, and long-term commitment to the industry.
• Control of their compliance destiny — they set and own their compliance calendar, policies, and training rather than inheriting a group framework.

If an incident identified through file reviews is determined to be a reportable breach, Cornerstone can lodge a breach report to ASIC on your behalf.

Maintain your compliance arrangements, pay annual levies, and notify ASIC of any material changes to your business.

1. Their conduct stops flowing up to you. A broker who holds their own ACL is no longer authorised under yours. They carry responsibility for their own conduct — their own compliance arrangements, and their own accountability to ASIC. The chain of responsibility between their day-to-day lending activity and your licence is severed.

2. Smaller representative book, smaller blast radius. Every ACR that moves on from your licence reduces your risk profile. ASIC's surveillance, targeted campaigns, and breach statistics draw heavily on licensee-level data; a leaner, more mature group of remaining representatives is far easier to supervise effectively.

3. Stronger supervision story. You are required as a condition of your own licence to have adequate arrangements to monitor your representatives. A group of individually licensed businesses — each with their own compliance arrangements — is no longer your problem. There are fewer moving parts under your direct authorisation.

4. Dispute and remediation isolation. If a client dispute or ASIC investigation arises from one broker's conduct, a broker holding their own ACL is the respondent in the first instance. Where the broker sits under your licence, the dispute, the remediation obligation, and the reputational damage land at your feet.

5. Contract and commercial clarity. An ACL-holding broker contracts with you as an independent licensee rather than as a representative. Your agreements can be structured around services provided by a licensed business rather than conduct you are legally answerable for.

Yes. Cornerstone offers a Current Compliance Arrangement Audit, a comprehensive review of your current framework and arrangements. Pricing is provided on application.

Yes. They can still aggregate through your platform — however the compliance risk is greatly reduced when they are no longer your ACR.

An ACL-holding broker contracts with you as an independent licensee rather than as a representative. That changes the risk allocation: your agreements can be structured around services provided by a licensed business rather than conduct you are legally answerable for.

ASIC may request further information. Respond promptly and completely — delays here are the single biggest cause of extended timelines.

A detailed report is provided after each review, plus aggregate reports showing overall trends for both the individual broker and the business. Reviews are carried out by a network of trained contractors and include:

• AML/KYC check
• Disclosure document check
• Responsible lending obligations
• Privacy and consent check

As the holder of an Australian Credit Licence (ACL), you are responsible for the conduct of every Authorised Credit Representative (ACR) you authorise under your licence. Every mortgage or finance broker operating under your authorisation is an extension of your licence — their compliance failures are, in ASIC's eyes, your compliance failures.

The more ACRs you authorise, the wider your exposure becomes: responsible lending breaches, credit guide and disclosure failures, complaint-handling failures, and any other conduct that can trigger licence investigations, enforceable undertakings, or in serious cases cancellation.

Encouraging experienced representatives to obtain their own ACL is one of the most effective structural ways to manage that exposure.

Submit your application to ASIC, pay the relevant fee and provide all supporting documents.

Yes. Cornerstone can look after the annual lodgement of all ASIC-required documents and returns for your brokers, including the Annual Compliance Certificate and IDR lodgement.

A range of policies are available that Cornerstone tailors and white labels, including:

• Compliance Plan
• IDR Policy
• Conflicts of Interest Policy
• Responsible Lending Policy & Guidelines
• Compliance Calendar
• Training Policy
• Adequacy of Resources Policy
• Best Interests Duty (if required)

Organise your AFCA membership and arrange Professional Indemnity insurance cover. Both are required before ASIC will grant the licence.

Yes. Cornerstone manages ACL applications for your brokers from start to finish, ensuring each application has the highest chance of success.

Cornerstone is a lean Brisbane-based team that keeps everything onshore for data security, risk reduction and familiarity. Its philosophy is to be at arm's length and in your corner, keeping compliance standards high while educating your Authorised Credit Representatives to meet industry expectations and regulations.

• Scale up or down: the structure lets you respond quickly to changes in business and the compliance landscape without hiring (or letting go) extra resources.
• Save on costs: no holiday or sick pay for employees outside your core services.
• Focus on core business: hand the mundane compliance tasks to a complementary team that holds itself to the highest standards.

Have your governance documents ready to go, or make arrangements to have them drafted — for example, your Compliance Plan and your Risk Management Policy.

Cornerstone is focused on reducing risk for aggregators, ACL holders and authorised credit representatives alike.

One way an aggregator can minimise risk is by encouraging experienced brokers and brokerages to transition from ACRs to obtaining their own ACL. This takes the pressure off you as the aggregator to hold all the compliance burden.

Cornerstone knows the ins and outs of ASIC and how to get a credit licence application right the first time.

The landscape: the industry has changed a lot in recent years and compliance is the backbone of any financial offering.

The customer: with a more educated customer base, it is paramount that your brokers do right by their customers. It is in their best interest and yours.

The competition: the finance industry is highly competitive. Compliance should not weigh your brokers down, so having a specialist team in their corner helps them stay compliant while they compete.

Select individuals with the skills, knowledge and experience to oversee each authorised activity, and document their qualifications and industry experience. Remember, they must be involved in day-to-day decision making once the licence is granted.

Licensees must maintain compliance with credit legislation at all times. That includes:

• Adequately supervising representatives
• Maintaining appropriate levels of competence and resources in the business
• Managing conflicts and risks

Cornerstone Compliance helps lighten that load by reducing risk to your ACL and supporting your panel of Authorised Credit Representatives to stay compliant and profitable, so your aggregation business can focus on growing.

Identify precisely which credit activities you intend to perform — broker, lender, asset finance or residential. Each carries different obligations, and your authorisations also shape the Responsible Manager requirements, the fee tier, and the compliance framework you must build.