• NCCP Requirements • Greg Ashe
The CompliFast Team is aware that some aggregators are finally, after over a decade, asking the question of their Licensee members "Are you managing your ACL properly?".
Of course you are, you have CompliFast. Hello aggregators and welcome to the party!!
At CompliFast, we have been pushing this message since day one! This is what sets CompliFast apart as the only comprehensive compliance management tool in the mortgage broking area that truly helps you to meet all of your Section 47 obligations under the NCCP Act.
Compliance management is governed by an international standard - ISO 37301. According to the Standard, this is how it works:
- Identifying all your obligations - that means all obligations, not just NCCP!
- Identifying controls that ensure you will meet your obligations - many of these will already exist in your business.
- Periodically testing the controls - to make sure they still work.
- Documenting the testing - this proves that it took place.
- Documenting and executing corrective actions where the testing has identified errors.
- Regularly reviewing the whole system to make sure it is still working and relevant.
"All" obligations includes not just Responsible Lending, Best Interests Duty, s47 General Conduct Obligations but also any amount of other legislation that you are obliged to comply with, including taxation, competition & consumer law, workplace health & safety, Corporations Act, ASIC Act - just to name a few.
Then there's the obligations to yourself! All those things that you always said you would or would not do in your own business. Then what about your business partners that you have legal agreements with - like your aggregator and the lenders that you are accredited with? These are obligations to be tested too.
CompliFast is the only platform that gets you to test ALL of these things and then automatically generates the detailed reporting about how the testing was done, what the results were and what actions need to be taken as an outcome.
Not only this, for the past year, CompliFast has also been actively alerting you (no one else) to potentially reportable breaches of your ACL obligations. Again, there is NO system in the country that delivers this.
Aggregators have told us "We cannot and do not want to rebuild what CompliFast has in its capabilities." So if your aggregator suggests to you that you might not have what it takes to fulfil on your ACL obligations, make sure you tell them - "It's okay - we're with CompliFast!"
If you know someone who may need benefit from the CompliFast system, please pass on our details.
