An Australian Credit Licence (“ACL“) holder is required by law to have various compliance measures in place. Sophie Grace understands the frustration associated with a “one size fits all” approach. We will design compliance procedures that are appropriate to the size, structure and activities of your credit business.
Sophie Grace prepares all compliance procedural documentation to address the obligations imposed on ACL holders. Our ACL compliance program documentation has been drafted to meet the compliance obligations as set out in:
- the National Consumer Credit Protection Act 2009;
- the National Consumer Credit Protection Regulations 2009;
- the National Consumer Credit Protection Amendment (Debt Management Services) Regulations 2021;
- ASIC Regulatory Guides;
- Australian Credit Licence conditions; and
- other relevant financial services laws.
Each of the procedures below, once tailored to your business, will form part of a body of documentation required by ASIC when obtaining and holding an ACL. This suite of documents is called a Compliance Program. The following procedures are available at Sophie Grace for purchase separately or together at a discounted price. Please click on each of the following policies and procedures to learn more about each template:
- Adequacy of Resources Policy;
- AML/CTF Policy;
- Breaches and Incidents Policy and Register;
- Complaints Register;
- Compliance Plan;
- Compliance Calendar;
- Conflicts of Interest Policy and Register;
- Credit Representatives Manual;
- Dispute Resolution Policy;
- Document Retention Policy;
- External Service Provider Register;
- Hardship Policy;
- Marketing Checklist;
- Outsourcing Policy;
- Representatives Policy;
- Responsible Lending Policy;
- Vulnerability and Hardship Policy (debt management providers only);
- Risk Management Policy and Matrix; and
- Training Policy.
Please note that not all the procedures listed will apply to each ACL holder. If you would like to obtain further information or assistance, please contact Sophie Grace directly or refer to the ACL Compliance Program Package below.