Broker guide
Credit Licence Responsible Manager Template
Connect ACL responsible manager training and experience to duties, competence evidence and succession using a template built for credit licence records.
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A credit licence responsible manager template records what each manager supervises, the evidence supporting their competence and who covers their duties during an absence. Use the tables below for an Australian credit licence (ACL) application or your existing licensee’s competence records.
The record connects a person’s experience to the credit activities your business conducts. A qualification certificate alone doesn’t explain whether that person can supervise the work you assign them.
The Australian Securities and Investments Commission (ASIC) assesses credit organisational competence under Regulatory Guide 206: Credit licensing: Competence and training. Australian financial services licence (AFSL) responsible manager requirements use Regulatory Guide 105 and a separate licensing framework.
Describe the Credit Business and Role
Describe your credit activities first, then give each responsible manager a defined supervision role and authority to act. Copy the fields below into your records and complete a separate role record for each manager.
| Field | What to record |
|---|---|
| Business identity | Legal entity, trading name, ACL number or application reference and record date |
| Licensed activities | Activities authorised or sought, with the licence or application reference |
| Actual business | Products, client types, locations, representative numbers and how credit assistance is delivered |
| Manager identity | Name, position, contact details and appointment date |
| Supervised activities | Exact credit work the manager oversees, including the people and locations covered |
| Decisions permitted | File review decisions, supervision directions and authority to stop work within the assigned role |
| Decisions escalated | Matters outside the manager’s competence or authority, with the person who receives them |
| Availability | Days or hours allocated, other commitments, contact method and response arrangements |
| Other responsible managers | Names, their areas of responsibility and where responsibilities overlap |
| Approval record | Person approving the role, date and next review date |
For example, write that a manager supervises home loan credit assistance by four brokers and reviews files before lodgement. Describe which files need their review and what happens when a file fails it.
Avoid a role description that says only that the manager oversees compliance. It leaves staff unable to tell who can stop a file, who handles an urgent issue or who covers the manager’s absence.
Connect the Role to the Licence
Keep a copy of your authorisations and conditions beside the role records. Record whether the licence names a person in a key person condition, which ties organisational competence to the named person’s continued involvement.
ASIC’s credit licence application guidance asks for responsible managers’ qualifications and relevant work experience. The Australian credit licence guide explains the wider application and how these records fit into it.
If two managers share supervision, allocate each task to one person and name the handover point. For example, one manager reviews routine home loan files while the other approves a change to the brokerage’s file-review procedure.
Attach Competence Evidence
Attach evidence for each competence claim and explain how it supports the manager’s proposed duties. Use one row per qualification or period of relevant work, so a reviewer can trace the claim to its source.
ASIC’s April 2020 RG 206 sets a baseline of two years’ relevant problem-free experience and an appropriate qualification. For third-party home loan credit assistance, responsible managers need at least a Certificate IV in Finance and Mortgage Broking.
| Evidence field | What to record |
|---|---|
| Competence claim | Credit activity or supervision duty the person can perform |
| Qualification | Full course title, issuer, completion date and certificate reference |
| Work history | Employer or licensee, role, exact dates and relevant credit activities |
| Practical responsibilities | Decisions made, files reviewed, staff supervised and limits on the role |
| Reference | Referee’s name, position, contact details and what they can confirm |
| Supporting record | Certificate, employer letter, supervision record or other evidence, with a storage reference |
| Connection to current duties | Why this evidence supports the assigned responsibilities |
| Evidence status | Established, partly established or not established, with the reason |
| Assessment | Reviewer’s name, assessment date, decision and action required |
A résumé can help you find the periods of work to document. Support the relevant periods with records that show what the person actually did.
Fictional Competence Record
Harbour Credit Pty Ltd is a fictional home loan brokerage. Its proposed responsible manager, Mia Chen, will supervise routine residential credit assistance and the brokerage’s file-review process.
| Claim | Evidence recorded | Assessment in this fictional example |
|---|---|---|
| Relevant qualification | Certificate IV in Finance and Mortgage Broking, completed in June 2021. Certificate Q-01 inspected. | Established for the qualification claim |
| Three years of residential credit assistance | Employment from July 2021 to June 2024. Employer letter E-01 confirms duties and dates. | Established for the described work period |
| Supervision of six brokers | Mia’s résumé lists this responsibility. E-01 confirms credit assistance work but does not confirm supervision. | Not established. Obtain a supervisor reference describing her authority and supervision work. |
| Commercial credit supervision | No relevant work period or qualification is recorded. | Not established. Commercial supervision is excluded from Mia’s assigned role. |
Mia’s unsupported supervision claim stays visible in the record until evidence supports it. Harbour assigns supervision authority only after assessing the evidence for that duty.
The distinction prevents an established credit assistance work history from silently becoming proof of every management responsibility. The fictional dates demonstrate how to record evidence, not an ASIC decision about Mia.
Fictional Absence and Urgent File Scenario
Harbour’s responsible manager, Daniel Ross, is unavailable from 5 to 9 October 2026. Another existing responsible manager, Priya Shah, covers Daniel’s routine residential file supervision under a written handover.
Priya’s competence record supports that work and she has access to the files and review procedure. On 6 October, a broker asks to lodge a file urgently despite missing income evidence.
| Cover detail | Harbour’s fictional arrangement |
|---|---|
| Named replacement | Priya Shah, existing responsible manager for residential credit assistance |
| Permitted decision | Require the missing evidence, review the completed file and authorise progress under Harbour’s existing procedure |
| Decision limit | Priya cannot waive the evidence requirement or approve a new supervision procedure |
| Immediate response | Priya stops the file from progressing until the required evidence and review are complete |
| Escalation | Priya refers any suspected compliance failure or requested procedure change to director Alex Tan that day |
| Uncovered work | Harbour pauses a task outside Priya’s assessed competence instead of treating the handover as permission to perform it |
| Return handover | Daniel reviews the decision log and outstanding actions on 12 October 2026 |
Priya can handle urgency within her competence and authority. Naming her as cover doesn’t increase either one.
Plan Ongoing Training and Succession
Keep responsible manager training, competence reviews and absence cover in one ongoing record, with actions assigned to named people. Responsible manager obligations continue after the licence application is approved.
RG 206 expects at least 20 hours of continuing professional development (CPD) per year for responsible managers. It also expects regular competence reviews and reviews when managers or business activities change.
| Ongoing record | What to complete |
|---|---|
| Review | Date, reviewer, activities examined, evidence inspected and outcome |
| Development need | Knowledge or supervision gap and the duty it affects |
| Training plan | Course or activity, learning objective, owner and completion date |
| CPD log | Date, topic, provider, hours and completion evidence |
| Learning applied | Change to a review procedure or supervision practice following the training |
| Absence cover | Replacement, evidence of competence, delegated limits, access and escalation |
| Succession | Duties at risk if a manager leaves, successor evidence and the transition steps |
| Change assessment | Effective date, effect on competence, licence conditions and notification decision |
| Sign-off | Person approving actions, completion evidence and next review date |
ACL responsible manager training must address the work the manager supervises. A course attendance record proves attendance, while the review records whether the learning addresses the identified gap.
In Harbour’s fictional plan, Priya completes training on reviewing irregular income by 30 November 2026. Daniel reviews her next relevant file decisions against Harbour’s procedure and records any further training needed.
Changes to Availability and Duties
Record a material change when a manager’s availability or duties change enough to affect how the business maintains competence. The internal record must show what changed and which work remains covered.
| Change field | Completed fictional example |
|---|---|
| Change and date | Daniel reduces supervision availability from five days to two days a week from 19 October 2026 |
| Reason for review | Three weekdays lose Daniel’s routine supervision coverage |
| Continuing coverage | Priya covers the other three weekdays within her established residential competence |
| Duties outside cover | Any work outside Priya’s assessed competence is paused and escalated to Alex |
| Conditions inspected | Alex reads the actual licence, including any condition naming Daniel |
| Notification assessment | Alex assesses the change against that condition, RG 206 and the current credit-licensee notification guidance before the change starts |
| Decision evidence | Alex records the applicable requirement, deadline, person responsible and any lodgement receipt, or the reason no notification is required |
| Follow-up | Daniel and Priya review file coverage after the first week and record unresolved actions |
RG 206 distinguishes a licence dependent on named key people from a business with responsibilities spread across several managers. It does not require notification of every responsible manager change in the latter case.
Read your actual licence conditions when deciding whether an absence, departure or reduction in duties requires notice or a variation. Keep the applicable requirement and deadline in the change record. Financial-services notification rules do not automatically apply to an ACL.
Before approving the record, trace each assigned duty to established evidence and a manager who is available to perform it. A duty with incomplete evidence or uncovered supervision remains an action to resolve before the business relies on that arrangement.
