Combined Industry Forum Progress Report:

Working towards a better mortgage broking industry for customersJuly 2018

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About UsIn 2017 the mortgage broking industry came together to form the Combined Industry Forum (the Forum), to take action on governance and remuneration practices to achieve better customer outcomes.

The Forum consists of representatives from banks and customer owned lenders, aggregators and brokers, consumer groups (represented through CHOICE), the Australian Banking Association (ABA), the Mortgage & Finance Association of Australia (MFAA), the Finance Brokers Association of Australia (FBAA), the Customer Owned Banking Association (COBA) and the Australian Finance Industry Association (AFIA).

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1. Executive summary 5

2. The mortgage broking industry in context 6

3. The CIF 7

3.1 Commitment of members, and membership profile 7

3.2 CIF members represent the industry 7

4. Response to ASIC Report 516 9

5. A determination to change: Industry-led reform and continuous improvement 10

6. Progress reporting 11

6.1 Reforms 1-4 11

6.2 Reforms 5-6 16

7. Other reforms – ‘Mortgage Broking Industry Code’ 17

8. The development of a ‘Customer First Duty’ 18

9. Next progress report 19

10. Appendices 20

10.1 Reporting template 20

10.2 CIF membership 23

Table of Contents

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1. ASIC Report 516, Review of Mortgage broker Remuneration, Mar 17: available at https://asic.gov.au/media/4213629/rep516-published-16-3-2017-1.pdf

2. Retail banking remuneration review: available at https://www.betterbanking.net.au/wp-content/uploads/2018/01/FINAL_Rem-Review-Report.pdf

1. Executive summary

The Combined Industry Forum (CIF) is pleased to provide this progress update outlining the mortgage broking industry’s efforts towards delivering improved customer outcomes.

In November 2017, the CIF released its report responding to the proposals outlined in ASIC’s 2016 Review of Mortgage Broker Remuneration1 and also considered the third-party recommendations of the Australian Banking Association’s 2016/17 Retail Banking Remuneration Review (Sedgwick Review)2.

The CIF’s reforms were developed to:

• ensure better customer outcomes,

• preserve and promote competition and customer choice, and

• improve standards of conduct and culture in mortgage broking.

The first key milestone in implementation of these reforms has recently been reached with members reporting that their goals with respect to Reform 2 have been achieved. Reform 2 related to the move away from volume-based bonus commissions, campaign-based commissions and volume-based bonus payments. This is an important step for the mortgage broking industry towards improving customer outcomes.

CIF members have reported progress across all six reforms outlined in the final report. Three workstream groups have been established involving CIF members to further develop the remaining reforms.

The CIF is also currently considering how it can build on the ‘Good Customer Outcome’ reform outlined in its final report and extending it by incorporating a ‘conflicts priority rule’ to be known as a ‘Customer First Duty’. This duty is still under development by the CIF, but the intention is for it to be based on an easy to follow principle: putting the customer’s interests first and matching the needs of the consumer with the right home loan product and lender.

The CIF is committed to providing regular updates to regulators on the progress made by members in addressing the reforms outlined in the report.

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2. The mortgage broking industry in context

After the publication of the ASIC Report and the Sedgwick Review, the mortgage broking industry has been working towards better customer outcomes while maintaining strong stakeholder confidence. These efforts have been coordinated by the CIF and include all parts of the mortgage broking value chain, including mortgage brokers, aggregators, lenders, industry associations and consumer groups.

While this work progresses, consumers continue to benefit from the availability of the mortgage broking channel for assistance with product comparison and loan applications. A review of the industry’s complaints data and of ASIC disciplinary activities since the publication of the last CIF report in December 2017 shows that:

• mortgage broker membership of the Credit and Investments Ombudsman (CIO) service has almost tripled since 2008, so that brokers represented 91% of CIO membership. However, complaints about brokers represented just 6.1 per cent of all complaints to the CIO, with the proportion of complaints relative to CIO broker member numbers halving since 2008;

• mortgage brokers also accounted for just 1 per cent of complaints to the Financial Ombudsman Service (FOS); and

• ASIC has secured 15 convictions of brokers between 2010 and 2017, which represents 1 in 9,000 brokers per annum.3

This data provides important context to the work of the CIF. It demonstrates that consumers are not complaining at levels that indicate high levels of public concern about mortgage broker behaviour.

3. MFAA unpublished data

Consumers are not complaining at levels that

indicate high levels of public concern about mortgage

broker behaviour.

mortgage brokers also accounted for just 1 per cent of complaints to the Financial

Ombudsman Service

ASIC has secured 15 convictions of brokers

between 2010 and 2017

A review of the industry’s complaints data and of ASIC disciplinary activities since the

publication of the last CIF report in December

2017 shows that:

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3. The CIF

3.1 Commitment of members, and membership profile

The CIF has 37 members committed to delivering reform. This represents a large cross section of the industry, particularly given the reach that members have through the value chain. Earlier this year, members contributed a membership levy to pay for legal and secretariat support of the CIF and confirmed their individual decisions to commit to achieving the objectives of the CIF, and in turn exercising their choice to implement these changes as appropriate in their businesses.

In addition to the main CIF group, there are 3 workstreams focused on addressing ASIC’s proposals. These workstreams all have at a minimum, a large and small lender, an aggregator, a broker representative, and association representatives to ensure debate is reflective of all parts of the industry value chain.

3.2 CIF members represent the industryThe CIF members capture most of the lending and aggregators and, by extension, brokers in the industry. The current CIF membership of lenders captures 87.6% of residential mortgage loans written by lenders for year to April 2018.

Aggregators represent a similar proportion in relation to their representation of the industry. It is estimated that combined, the aggregators who form part of the CIF represent more than 87% of the Australia broker market4 (based on volume of $ written).

4. MFAA, data via Corelogic unpublished – note that this data is confidential and omits one CIF member, so number is likely to be higher than the percentage provided.

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4. Response to ASIC Report 516

The CIF is working to implement a reform program across the mortgage broking industry to facilitate better customer outcomes through improved governance and remuneration practices.

To progress the work as quickly as possible, three workstreams have been established across all the CIF reforms:

Workstream 1 (Reforms 1 to 4)

This workstream is responsible for establishing a reporting framework to track industry progress on addressing ASIC’s proposals to:

• Change the standard commission model to reduce the risk of poor consumer outcomes

• Move away from bonus commissions and bonus payments which increase the risk of poor customer outcomes

• Move away from soft dollar benefits which increase the risk of poor customer outcomes and can undermine competition, including consideration of the following specific areas:

– Tiered servicing

– Conferences and professional development

– Entertainment and hospitality

– Lender sponsorship of aggregator events

• Have a clearer disclosure of ownership structures within the home loan market to improve competition

Workstream 2 (Reforms 5 and 6)

This workstream is responsible for progressing and measuring the industry’s response to ASIC’s proposals to:

• Establish a new public reporting regime of customer outcomes and competition in the home loan market

• Introduce an improved governance and oversight of brokers by lenders and aggregators

Workstream 3 (Code of Conduct)

This workstream is responsible for the industry reform to develop an industry code that enables enforcement, applies across the industry, and includes new participants over time.

Some aspects of the reform package – particularly those relating to ASIC’s proposal for reform of remuneration structures (Reforms 1 to 4) – are impacted by Australian competition law. The industry is committed to acting on these areas, subject to developing an appropriate structure and meeting all competition law requirements. All CIF meetings and relevant workstream meetings are held with independent legal representation present, to ensure compliance with competition laws.

The CIF is working to implement a reform program across the mortgage broking

industry to facilitate better customer outcomes

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5. A determination to change: Industry-led reform and continuous improvement

5.1.1 Industry-led initiativeThe CIF is moving forward with integrating good customer outcomes and placing the customer at the centre of a self-regulation model that currently contemplates:

• Improved data gathering initially through self-reporting, with Key Risk Indicators (KRIs) that assist in identifying trends and issues which have the potential to become systemic.

• A comprehensive governance framework, that incorporates a mortgage industry code of conduct, Regulatory reporting, and an oversight and enforcement regime.

• A continuous improvement regime, that identifies issues and either modifies elements of the Governance structure as needed and provides feedback to organisations for remedial training and professional development.

CIF members have commenced work towards a governance and reporting structure that will build on existing self-regulation arrangements. Subject to compliance with competition laws, the CIF is also investigating how the industry’s self-regulation efforts could be monitored and assessed over time.

5.1.2 Positioning the industry in today’s environment for the future

The regulatory landscape for credit and financial services is likely to see industry change for years to come. At the time of writing, work is continuing as part of the Royal Commission into Misconduct in the Banking, Superannuation and Financial Services Industry, the ACCC Residential Mortgage Products Price Inquiry, and the Productivity Commission’s Report into Competition in the Australian Financial System. It is likely that these processes will result in further changes to the industry and the mortgage broking value chain. However, until there is more certainty as to what those changes might be, the CIF will continue to focus on the Sedgwick recommendations and ASIC proposals to build a platform for the future. In doing so, the CIF will continue to make efforts that aim at improving customer outcomes, while maintaining the commercial viability of the industry, and promoting competition.

Looking to the future, the CIF is also considering how best to work with regulators to enhance its efforts. The second half of 2018 will see more engagement as the CIF makes further progress on reform and seeks feedback from Government and regulators.

The CIF is moving forward with integrating good

customer outcomes and placing the customer at the centre of a self-regulation

model

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6. Progress reporting

6.1 Reforms 1-4 The following outlines the progress for each of the first four recommendations. A more detailed analysis can be found at 10.1.

In response to ASIC’s proposal for changing standard commission models, CIF considered that industry participants may adopt the following remuneration principle: “To the extent that remuneration relates to loan size, remuneration should relate to the funds drawn down and utilised by a customer”. Respondents have noted that for the most part this work is well underway. The work is contingent on project management and change management particularly in relation to training and communication. There were several comments that identified that amendments to legal agreements and system changes will be necessary to finalise the implementation of this reform.

6.1.1 Remuneration and loan size

Nov 2017

Not commenced

Assessment of impact

Well progressed

Complete Dec 2018

In progress

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Industry recognised ASIC’s expectation that there should be a move away from volume-based bonus commissions, campaign-based commissions and volume-based bonus payments paid by lenders and aggregators. Accordingly, since the commencement of the CIF, industry participants have been making individual decisions to meet ASIC’s expectations and move away from these commissions and payment structures.5

It is worth noting that the industry has undertaken highly detailed analysis of mortgage products to ensure full compliance and in doing so has identified that there are contracts that had to be amended or restructured to meet these requirements. This resulted in some delays in finalising the process for certain industry participants, but participants have reported that this process has now been completed.

6.1.2 Moving away from bonus commissions and bonus payments

Not commenced

Assessment of impact

Well progressed

Complete Dec 2017

In progress

5. Several industry participants have never paid or received these types of commissions. Further, there were some members who, for contractual reasons could not close off these payments by the December 2017 deadline. The attestation process has captured these products, which have ceased to operate with such a payment structure.

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CIF’s proposed response to ASIC’s recommendations considered four areas:

• Tiered servicing Access to a lender or aggregator’s tiered service model should be determined using a balanced scorecard, with a maximum 30% volume component, as a proxy for productivity, as well as other criteria aligned to ‘Good Customer Outcomes’.

Access to a tiered service model to be disclosed by the broker where they are recommending a product from a particular lender.

Such programs should not entitle brokers to preferential customer discounts or to additional payments or commissions. Instead, these programs should provide preferential service which can assist customers in achieving better outcomes.

• Conferences and professional development Professional development and most education is available to all brokers to ensure ongoing competency and professional development. All conferences and professional development events must be educationally focussed (with a minimum of 80% identified education content) and aimed at continually improving customer outcomes.

Minimum education and professional development for brokers is not considered a reward but as driving a level of competency to improve customer outcomes.

Locations for conferences and professional development must be business appropriate and not likely to cause reputational harm to the industry.

In some circumstances, additional education opportunities are offered. Broker access to these additional opportunities should be based on a balanced scorecard, that does not include volume.

• Entertainment and hospitality The industry recognises the provision of high-value entertainment and hospitality may raise the risk of lender choice conflicts. The industry considers that this risk may be addressed by ensuring that lenders do not provide entertainment or hospitality to mortgage brokers which goes above the amount allowed under Fringe Benefits Tax (currently $350 per person, per event) to enable lenders and aggregators to use existing reporting for better monitoring and supervision.

Aggregators will not determine eligibility for entertainment or hospitality, wholly or partly, on the volume of loans written with any one lender or white label loan product.

For entertainment or hospitality above $100, lenders, aggregators and brokers will be required to maintain their own register of entertainment and hospitality benefits (given or received) on a rolling 12-month basis, with records kept for three years.

‘Entertainment and hospitality’ does not include professional development and education events, that have more than 80% identified education content and are offered in a business appropriate location.

This register should be kept current, advertised in the Credit Guide provided to customers and monitored by aggregators and details provided on request.

• Lenders sponsorship of aggregators events Sponsorship opportunities to an aggregator event should be made available to the aggregator’s entire lender panel. As above, the aim of any event is to increase education. Further, the ability to join an aggregator’s panel should not be contingent on the level of sponsorship provided.

6.1.3 Moving away from soft dollar benefits

Nov 2017

Not commenced

Assessment of impact

Well progressed

Complete Dec 2018

In progress

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CIF members are demonstrating strong progress in relation to these reforms, with many noting they need to either modify existing registers or update existing policies to reflect the new requirements. Most organisations have noted that they are progressing towards achieving their intended changes in relation to soft dollar requirements.

The CIF is currently working on definitions of some terms that are proving to be difficult to find consistent definitions of, with the 80/20 rule relating to 80% of conference and professional development being required to directly relate to the work of attendees. Defining this term, which will in part be guided by existing practices industry associations for PD points will assist members to implement this reform in their business.

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The disclosure of ownership structures has seen moderate progress. For many lenders (large and independent), there is no requirement to declare their ownership as they are the sole entity. Others have comprehensive disclosure already in place and have completed this requirement.

Remaining organisations are deciding where the disclosure would be presented in their documentation. One of CIF’s workstreams is considering this question, recognising that in some circumstances this level of disclosure may be over and above current regulatory requirements. Most respondents who will need to implement these changes have started the implementation process.

6.1.4 Clearer disclosure of ownership structures

Nov 2017

Not commenced

Assessment of impact

Well progressed

Complete Dec 2018

In progress

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The workstreams focussing on Reforms 5 and 6 are initially focussing on a framework for data standardisation and consistent understanding of governance and public reporting requirements. The development of this framework is expected to be a driver for continuous improvement in the industry.

Work on the public reporting framework has started, with the relevant workstream initially focussing on having a clear understanding of data needs and a common approach to definition of key terms. The workstream will engage with ASIC once work is further progressed and we hope to gain specific insight on the design of the consumer disclosures. This phase of work is scheduled to be completed by the end of 2018.

In relation to Reform 6, while implementation is not expected until the end of 2020, the CIF’s aim is to make rapid progress towards building up the governance structure with a view to a staged rollout, starting this year. This is important to smooth costs for organisations when implementing the changes, and to assist them to access adequate project funding in their budget cycle.

Nov 2017

Not commenced

Assessment of impact

Well progressed

Complete Dec 2018

In progress

6.2 Reforms 5-6

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The CIF outlined in its final report that it would investigate the development of a ‘Mortgage Broking Industry Code’ (the Code) that captures all the reforms, enables enforcement and could include new participants over time.

Workstream Three is responsible for overseeing the development of the Code and has already completed work on identifying gaps in the existing regulatory structure and existing codes of conduct. It has now shifted its focus towards drafting of the code with the intention that it will form the basis of expected behaviour in the industry, with industry associations providing overlays that outline the expectation of their members over and above the minimum.

The code development will follow the processes that would support an application for ASIC approval under Regulatory Guide 183: Approval of financial services sector codes of conduct6. The CIF is however taking a pragmatic approach and recognises the need for the Code to be developed and in place, with the option of pursuing appropriate ASIC approval at a later time or in parallel. The timing of possible ASIC approval will in part be informed by other regulatory inquiries underway.

The CIF is specifically looking at appropriate enforcement and oversight mechanisms, as well as mechanisms to enable the CIF members to respond in cases of breaches of the code.

Nov 2017

Not commenced

Assessment of impact

Well progressed

Complete Dec 2018

In progress

7. Other reforms – ‘Mortgage Broking Industry Code’

6. Note this Regulatory Guide only applies to financial services (Corporations Act). There is no equivalent for the NCCP Act.

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8. The development of a ‘Customer First Duty’

Throughout 2018, the CIF has been considering ways to build on the “Good Customer Outcomes” reforms made in the November 2017 report.

The Good Customer Outcome reflects, and adds to, the regulatory requirements that currently exist for brokers. The November 2017 response to ASIC defined ‘Good Customer Outcomes’ as an outcome where:

“ The customer has obtained a loan which is appropriate (in terms of size and structure), is affordable, applied for in a compliant manner and meets the customer’s set of objectives at the time of seeking the loan.”

It further noted:

“A ‘Good Customer Outcome’ is at the centre of what we are striving to achieve whether lender, aggregator, mortgage broker or other industry participant. The above definition sets out four key measures that need to be satisfied to determine a ‘Good Customer Outcome’:

• Appropriate size and structure of the loan,

• Meeting the customer’s stated requirements and objectives,

• Affordability for the customer, and

• Applied for in a compliant manner (meeting all responsible lending requirements).”

The CIF has agreed in principle to extend this requirement to also incorporate a ‘conflicts priority rule’ as a ’Customer First Duty’. The ‘conflict priority rule’ could be formulated as a requirement for the customer’s interests to be placed above the providers, or those of their organisation, based on the information reasonably known to the provider, at the time of providing the service. The effect of this approach would be a requirement to place the customer’s interests first.

The combination of the good customer outcome definition and a customer first duty allows both an easy to follow principle – put the customer’s interests first - and structure to follow for brokers when assessing loan suitability. Further governance metrics can be built around this concept for monitoring and oversight.

In forming a common position for the CIF, it is evident that the development and application of a customer duty is multi-faceted and complex, and there may be unknown impacts. These include the potential for limiting access to credit, and a disproportionate impact on smaller and regional lenders if lender panels require rationalisation.

While the CIF has not settled on a final position, it has, agreed on the following key principles that should underpin any reform:

• placing the customer first, and having ‘good’ consumer outcomes at the centre of its approach

• fit-for-purpose for the mortgage broking industry, considering the nature of services provided, the form of conflicts of interests inherent to the industry, the current evidence of risks to customer outcomes, and considering the current regulatory framework

• promoting competition, and ensuring that no part of the value chain is unfairly disadvantaged

• all parts of the value chain will have a role to play to support the implementation and monitoring the customer duty

• providing transparency for all participants, and

• promoting simple, achievable solutions.

Finally, the CIF is aware that there is merit in moving a customer first principle from an implicit expectation, to an explicit statement that a customer and mortgage advice provider can easily understand.

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9. Next progress report

The CIF is committed to keeping Treasury and Regulators informed about industry progress in responding to ASIC Report 516.

In the initial report, the CIF committed to reporting on the following milestones:

In addition to the above the CIF has also started work towards developing a Mortgage Broking Industry Code and is aiming to have a version in place by end 2018.

The CIF intends to provide Treasury with an update on progress in early December 2018. A finalisation report of member’s implementation of Reforms 1-5 which are scheduled to be in place by 31 December 2018 will be delivered in first quarter 2019. The implementation of actions contained in proposed Reform 6 are scheduled to be implemented on a staged basis through to the end of 2020, with progress reporting continuing as required, on a six-monthly cycle.

ASIC’s proposal Proposed implementation

Changes to the standard commission model End of 2018

Move away from bonus commissions and bonus payments End of 2017

Moving away from soft dollar benefits End of 2018

Clearer disclosure of ownership structures End of 2018

Establishing a new reporting regime End of 2018

Improved governance and oversight of brokers End of 2020

December 2018 Progress Report

March 2019 Reforms 1-5 Final Report

Progress Reporting on Reform 6 through

to 2020

Timeline

June 2018 Progress Report

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duca

tion

cont

ent)

and

aim

ed a

t co

ntin

ually

impr

ovin

g cu

stom

er o

utco

mes

• A

ll lo

catio

ns fo

r co

nfer

ence

s an

d pr

ofes

sion

al d

evel

opm

ent m

ust b

e bu

sine

ss a

ppro

pria

te a

nd n

ot li

kely

to

caus

e re

puta

tiona

l har

m to

the

indu

stry

• A

ny a

dditi

onal

edu

catio

nal o

ppor

tuni

ties

bein

g of

fere

d to

bro

kers

are

bas

ed o

n a

bala

nced

sco

reca

rd, w

hich

doe

s no

t in

clud

e lo

an v

olum

e

Ent

erta

inm

ent

and

ho

spita

lity

• N

o en

tert

ainm

ent o

r ho

spita

lity

to b

e pr

ovid

ed b

y le

nder

s to

bro

kers

ove

r th

e va

lue

of $

350

per

pers

on, p

er e

vent

and

no

t bas

ed o

n lo

an v

olum

e

• A

ggre

gato

rs to

not

det

erm

ine

elig

ibilit

y fo

r en

tert

ainm

ent o

r ho

spita

lity,

who

lly o

r pa

rtly,

on

the

volu

me

of lo

ans

writ

ten

with

an

y on

e le

nder

or

whi

te la

bel l

oan

prod

uct

• A

ll le

nder

s, a

ggre

gato

rs a

nd b

roke

rs to

m

aint

ain

a re

gist

er o

f ent

erta

inm

ent a

nd

hosp

italit

y be

nefit

s (g

iven

or

rece

ived

) on

a ro

lling

12-m

onth

bas

is w

ith re

cord

s re

tain

ed fo

r at

leas

t 3 y

ears

• E

nsur

e re

gist

er is

kep

t cur

rent

and

ad

vert

ised

in th

e C

redi

t Gui

de p

rovi

ded

to

cust

omer

s an

d m

onito

red

by a

ggre

gato

rs

and

deta

ils p

rovi

ded

on re

ques

t

22

Rec

om

men

dat

ion

Hav

e no

t co

mm

ence

d a

n as

sess

men

t o

f th

e im

pac

t

So

me

pro

gre

ss

mad

e in

im

ple

men

ting

the

re

qui

rem

ents

Wel

l pro

gre

ssed

in

imp

lem

entin

g

the

req

uire

men

ts

Imp

lem

enta

tion

com

ple

te

Rec

om

men

dat

ion

not

app

licab

le

(bas

ed o

n th

e ty

pe

of

bus

ines

s, b

roke

r, ag

gre

gat

or)

.

Wha

t ac

tiviti

es d

o y

ou

pla

n to

do

in t

he n

ext

3 m

ont

hs?

The

se c

an r

elat

e to

cha

nges

to

po

licie

s an

d p

roce

dur

es,

com

mun

icat

ion

and

tra

inin

g

and

cul

tura

l cha

nge

and

in

clud

e m

atte

rs r

elat

ing

to

th

is in

itiat

ive

as w

ell a

s o

ther

al

igne

d in

itiat

ives

out

sid

e th

e sc

op

e o

f th

is in

itiat

ive.

Hav

e th

ere

bee

n an

y ne

w

sig

nific

ant

imp

lem

enta

tion

risk

s id

entifi

ed s

ince

su

bm

issi

on

of

the

last

p

rog

ress

rep

ort

up

dat

e o

r ch

ang

es t

o p

revi

ous

ly

iden

tified

imp

lem

enta

tion

risk

s in

ach

ievi

ng t

he o

bje

ctiv

e/o

utco

me

of

the

initi

ativ

e?

Ple

ase

pro

vid

e d

etai

ls a

nd

des

crib

e w

hat

you

are

do

ing

to

man

age

thes

e ri

sks.

Lend

er s

po

nso

rshi

ps

of

agg

reg

ato

rs a

nd

even

ts

• P

rovi

de a

ny s

pons

orsh

ip o

ppor

tuni

ties

to a

n ag

greg

ator

eve

nt is

mad

e av

aila

ble

to e

ntire

lend

er p

anel

and

the

aim

of a

ny

even

t is

to in

crea

se e

duca

tion

• E

nsur

e th

e ab

ility

to jo

in a

n ag

greg

ator

’s

pane

l is

not c

ontin

gent

on

the

leve

l of

spon

sors

hip

prov

ided

Cle

arer

dis

clo

sure

of

ow

ners

hip

str

uctu

res

Dis

clos

e ow

ners

hip

stru

ctur

e if

of ‘S

igni

fican

t In

fluen

ce’ a

s gu

ided

by

AA

SB

128

– d

iscl

osur

e re

quire

d w

here

for

exam

ple:

• O

wne

rshi

p is

20%

or

grea

ter;

or

• W

here

ow

ners

hip

is le

ss th

an 2

0%, a

bo

ard

seat

is h

eld,

or

a w

hite

labe

l pro

duct

is

offe

red

by a

sub

stan

tial s

hare

hold

er.

(Nee

d to

ens

ure

this

app

lies

to le

nder

ow

ned

brok

er b

usin

esse

s)

Ens

ure

disc

losu

re o

blig

atio

ns e

xten

d be

yond

m

ortg

age

brok

ers

and

appl

ies

to a

ll pl

ayer

s in

ho

me

loan

dis

trib

utio

n ch

ain,

incl

udin

g le

nder

s an

d ag

greg

ator

s

23

10.2 CIF Membership

Organisation Type

ABA Industry Association

AFIA Industry Association

AMP Bank Lender

Astute Aggregator

Aussie Home Loans Aggregator

Australia and New Zealand Bank (ANZ)

Lender

Australian Finance Group (AFG) Aggregator

Bank Of Queensland/Virgin Money Lender

BeckMitch Consulting Broker

Bendigo and Adelaide Bank Lender

Choice Aggregation Services Aggregator

CHOICE Consumer Advocacy Group Consumer group

COBA Industry Association

Commonwealth Bank of Australia Lender

Connective Aggregator

Credit Union Australia (CUA) Lender

Divitis Finance Broker

FAST Group Aggregator

FBAA Industry Association

Foster Finance Broker

Organisation Type

Gilbert + Tobin Lawyers Ind. Legal Advisors

Heritage Bank Lender

ING Lender

Lendi Broker

Liberty Financial Aggregator

Loan Market Aggregator

ME Bank Lender

MFAA Industry Association

Mortgage Choice Aggregator

National Australia Bank Lender

NMB Aggregator

PLAN Australia Aggregator

Smartline Aggregator

SmartMove Broker

Suncorp Lender

Tailored Lending Broker

Vow/YBR Aggregator

Westpac Lender