Credit Guide Requirements for Mortgage Brokers

A credit guide tells your client who provides the credit service, how that business is paid and where to complain. For mortgage brokers, it belongs at the start of the engagement, as soon as providing credit assistance becomes likely. Keep the exact version you give each client and a record showing when they received it.

The guide is an early disclosure about your business. A fee quote and the credit proposal disclosure document have separate jobs and delivery points. Sending the guide doesn’t complete those later obligations.

Identify the Issuer and Timing

Identify the legal entity providing credit assistance and the licence under which it acts before selecting the guide. A trading name on the cover doesn’t identify the licence holder by itself.

Under section 113 of the National Consumer Credit Protection Act 2009, a licensee gives its guide as soon as practicable after credit assistance becomes likely. For a mortgage engagement, send it during onboarding, before suggesting a particular loan or helping the client apply. Waiting until lodgement can leave the disclosure late.

A credit representative generally gives its own guide at the same time as the licensee’s guide under section 158. You can combine them into one document if the document meets all applicable requirements. An employee of a licensee uses the licensee’s disclosure arrangements, so establish your actual role before inserting a representative number.

Fictional Representative Practice

This synthetic example illustrates the fields in a combined guide. All business names, identifiers and business contacts below are fictional.

Harbour Home Loans is the trading name of Harbour Credit Services Pty Ltd. That company is a credit representative of Southern Harbour Finance Pty Ltd, the Australian credit licence holder. Maya Chen provides the service as an authorised credit representative within this fictional arrangement.

Field	Fictional guide entry	What the client learns
Trading name	Harbour Home Loans	The brand used in appointments and emails
Representative entity	Harbour Credit Services Pty Ltd, credit representative number 000001	The company providing the representative service
Individual representative	Maya Chen, credit representative number 000002	The authorised broker handling the engagement
Licensee	Southern Harbour Finance Pty Ltd, Australian credit licence number 000000	The licence holder for the service
Authorised activity	Providing credit assistance for consumer home loans on behalf of Southern Harbour Finance Pty Ltd	The work the representative is authorised to perform
Business contact	clients@harbourhomeloans.example	How to contact the fictional practice
Internal complaints	Complaints Manager, complaints@southernharbour.example	Where the client first raises a complaint
External complaints	Australian Financial Complaints Authority (AFCA), 1800 931 678, afca.org.au	Where an unresolved complaint can go

The example uses real AFCA contact details. In an actual guide, use the complaint procedure and contacts for each relevant entity. Identify the practice’s complaint contact and explain how the licensee handles a complaint passed to it.

What the ANZ Credit Guide Covers

As at October 2026, ANZ’s important-documents page links to the ANZ Credit Guide. Its issuer is Australia and New Zealand Banking Group Limited, Australian Business Number (ABN) 11 005 357 522. It gives Australian credit licence number 234527 and the printed version code 08.2021, with item number 77452 and reference WZ109974.

That guide covers entering a consumer credit contract with the bank. It describes home loans and other consumer lending, the bank’s suitability assessment and how to request that assessment. It also explains that ANZ Mobile Lenders are appointed credit representatives for whose services ANZ is responsible.

The guide’s complaint routes are ANZ’s Contact Centre on 13 13 14 or a branch or business centre. It lists AFCA’s phone number as 1800 931 678 and postal address as GPO Box 3, Melbourne VIC 3001.

ANZ’s personal and home-loan terms page expressly excludes ANZ Plus Home Loans from the guide linked there. Match the document to the legal issuer and service. An independent broker arranging an ANZ loan still has its own disclosure duties under its own licence or representative arrangement.

Include the Required Information

Include identity and complaint information, then the disclosures that apply to your role as a licensee or credit representative. The Australian Securities and Investments Commission (ASIC) disclosure guidance explains the differences between those roles.

For a licensee providing credit assistance, the guide covers these subjects.

• The licensee’s legal name, contact details and Australian credit licence number.
• Fees and charges payable by the client, with how they are calculated unless a permitted request-based disclosure arrangement applies.
• Lender payments received directly or indirectly, including a reasonable estimate or range and the calculation method, subject to the permitted disclosure arrangements.
• The lenders the licensee conducts business with. Name them all if there are six or fewer, or the six with whom it reasonably believes it conducts most business.
• The internal complaints procedure and AFCA access details.
• The obligation to avoid unsuitable credit assistance and how the client can request the preliminary assessment.
• Applicable referral-payment and volume-bonus disclosures under the regulations.

For a representative, also identify the relevant licensees and the activities authorised on their behalf. Explain fees payable to the representative and indirect remuneration received from its licensees. The guide must contain the representative’s dispute procedure and applicable AFCA details.

Regulation 27A adds lender, referrer and volume-bonus information for representatives. Its combined-document exception removes the separate representative lender-list and volume-bonus requirements when the guide is combined with the licensee’s guide. The licensee’s applicable disclosures still belong in that document.

For mortgage brokers, disclosure of a payment doesn’t make prohibited conflicted remuneration permissible. Describe the actual lawful remuneration arrangement.

Worked Disclosure Example

Continue the fictional Harbour example with these assumptions. The practice charges clients no fee for credit assistance. Southern Harbour receives upfront and ongoing trail commission from lenders, then passes an agreed share to Harbour Credit Services.

The combined guide states that clients pay no broker service fee. It separately explains lender commission and how the representative is paid through the licensee. A lender’s application or valuation fee is a different charge and belongs in the relevant loan disclosures.

Suppose Southern Harbour conducts business with eight lenders. Its six most-used lenders in this example are Commonwealth Bank, ANZ, Westpac, NAB, Macquarie and ING. List those six in the licensee part of the combined guide.

If the practice pays a referral fee to an accountant who introduces a client, describe that class of referrer. Explain how the client can request an estimate and the calculation method. State the actual volume-bonus position, including who pays and receives any arrangement that must be disclosed.

Regulations 27 and 27B permit some calculation details and remuneration estimates to be supplied on request. The guide must tell clients they can request those details, and the business must have arrangements to provide them. A statement that commissions exist, without the required detail or request route, leaves the disclosure incomplete.

Give the Guide Before the Relevant Step

For the fictional client Alex, Harbour sends the combined guide before discussing a recommendation for a particular lender and loan. The following record illustrates evidence a practice can retain.

Record	Fictional file entry
Electronic-delivery consent	2 October 2026, 9:02 am AWST. Alex consents after receiving the electronic-delivery information
Document	Harbour combined credit guide, version 1.0, effective 1 October 2026
Delivery	2 October 2026, 9:05 am AWST. PDF attached to an email sent to Alex’s nominated address
Receipt evidence	2 October 2026, 9:14 am AWST. Alex replies that the attached guide was received
Next credit-assistance step	2 October 2026, 10:00 am AWST. Maya discusses a specific loan recommendation

AWST means Australian Western Standard Time. The acknowledgement supports the delivery record. It doesn’t establish that the client agreed with the guide’s content or that a later loan recommendation meets your obligations.

Deliver and Maintain the Guide

Deliver the guide through an allowed method and preserve the version delivered, so the file can show what the client received before further credit activity. Put a named staff member in charge of the current document and its distribution settings.

Regulation 28L of the National Consumer Credit Protection Regulations 2010 governs electronic delivery. Obtain consent after explaining the electronic-document conditions, including the client’s right to withdraw consent. Electronic documents must be capable of being saved and printed.

For website retrieval, notify the client promptly that the guide is available, identify the document and provide access for a reasonable period. Retain evidence that the client accessed it. A footer link alone doesn’t show that the guide was given to this client.

For a properly addressed guide sent to a nominated electronic address, regulation 28L permits reasonable satisfaction of receipt unless the client advises otherwise. A reply acknowledging an attachment is useful evidence, but the regulation doesn’t impose a universal signed acknowledgement. If the client reports a failed email or cannot access the guide, provide a usable copy before continuing.

Update Changed Fields and Retire the Old Version

Use a change log to connect each amendment to the effective document. The following changes create different update tasks for Harbour’s fictional combined guide.

Change	Fields to update	Distribution action
New licensee or changed authority	Licensee name and licence number, representative details, authorised activities, complaint route and remuneration relationship	Replace the onboarding document and send the applicable guide for the new arrangement
Introduction of a client service fee	Fee description, amount or calculation method and any statement that no fee is charged	Replace the guide and revise the quote process before the fee-bearing service
Changed commission or referral arrangement	Recipient, payer, remuneration description and calculation details or request route, plus applicable referrer disclosure	Update the guide and check affected proposal disclosures
Changed complaint arrangements	Complaint procedure, internal contact and AFCA access details where required	Replace the guide and all complaint-contact references
Changed most-used lenders	Relevant lender list	Update the list in the licensee guide or applicable separate representative guide

Regulation 28B permits a limited update period for some changed information that is less than 93 days old. The required AFCA contact details are excluded from that concession. A practice can adopt prompt replacement as its standard and avoid relying on the concession for routine updates.

In the fictional fee change, Harbour creates version 1.1 effective 12 October 2026 and marks version 1.0 retired from new-client use. Remove version 1.0 from automated onboarding emails and the public download. Preserve its PDF in the archive and in Alex’s file, alongside the original delivery evidence.

Record who authorised version 1.1 and why it changed. Keep the new guide’s delivery record separate from Alex’s earlier acknowledgement, so the archive preserves the sequence instead of rewriting it.

Before starting the next engagement, send yourself the onboarding pack and open its guide attachment or retrieval link. Confirm the issuer, version and complaint contacts match the approved current document. Use the mortgage broker compliance checklist to carry that document and delivery record into the rest of the client file.