For Aggregators

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.

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.

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.

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.

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

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)

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.

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.

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

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.

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

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.

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.

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.

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

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

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.

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.