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Broker guide

Mortgage Broker Fraud Checks and Escalation

Assess mortgage broker fraud concerns, including CommBank reporting, with payslip checks, preserved evidence and careful escalation before any accusation.

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Mortgage fraud is deliberate deception in a home loan application, such as false income evidence, concealed debts or using another person’s identity without authority. Mortgage broker fraud checks compare the application with reliable source records. When a discrepancy remains unexplained, pause the affected work and give your compliance owner the evidence before making an accusation.

A tidy payslip can contain false information. An untidy one can be genuine. The useful question is whether independently obtained evidence supports the identity and income the application relies on.

Recognise Warning Signs

Look for facts that conflict across identity, employment, income and bank records, then test the conflict before deciding what it means. A changed address, irregular salary credit or unusual document layout can have an ordinary explanation. A single anomaly doesn’t establish fraud.

The Australian Transaction Reports and Analysis Centre (AUSTRAC) reported mortgage-file concerns across major banks in Operation Claw on 19 August 2026. Its findings included inflated incomes, misrepresented employment and fabricated or unverifiable business activity. Those are checks to apply to a file, not findings about your client.

Part of the fileWarning signCorroborating check
IdentityNames or dates of birth conflict across recordsReconcile the difference through the approved identity process and source documents
EmploymentThe employer or role differs between the application and payslipConfirm employment through an independently obtained employer contact
IncomeSalary credits don’t support the payslip’s net payCompare the same pay periods and obtain an explanation for split payments or deductions
Bank recordsDeposits described as wages come from an unexplained sourceEstablish who paid them and why, using original transaction records
Business incomeDeclared activity doesn’t support the financial statementsReconcile business records with tax and bank evidence through an authorised source

Keep the check specific. An employer’s registered business name can differ from its trading name. A bank credit can arrive after the payslip date, and payroll can divide net pay between accounts.

CBA Mortgage Fraud Reports and Case Outcomes

Public reports of Commonwealth Bank of Australia (CBA) mortgage fraud need careful wording because a suspected application and a proven offence have different meanings. On 27 February 2026, 7NEWS reported suspected mortgage fraud referred to police, with some documents believed to involve artificial intelligence. That report doesn’t establish fraud in any particular client’s file.

The Australian Securities and Investments Commission (ASIC) also records a historical CBA matter with a clear outcome. Its 2019 release about former mobile lender Andrew Cameron states that a jury found him not guilty of conspiracy to defraud. The charge concerned alleged false documents supporting home loan applications.

Record allegations as allegations and retain the outcome when referring to a case. Don’t label a client or broker a fraudster because their documents resemble a reported case.

AI-Generated Applications in Australia

Artificial intelligence (AI) can help produce convincing false payslips or other application documents. It can also support fabricated identity details or combine stolen details with invented information, creating a synthetic identity. A matching name across several documents doesn’t prove that the applicant owns that identity.

In the 27 February 2026 7NEWS report, cybersecurity specialist Luke Irwin described stolen personal information used with AI tools to create false application documents. His suggested checks included confirming employment directly and verifying the applicant’s identity. AI changes how convincing a document can look, so appearance alone is a weak test.

Use the lender’s accepted verification of identity process to establish the person and their authority to apply. For income, compare source payroll evidence with salary credits. A document detector’s score can prompt review, but it doesn’t replace those checks or prove who created a document.

Synthetic Payslip Examples: Unexplained Gap or Variable Pay

These fictional records show two different reasons for a discrepancy. They describe verification decisions, not actual applicants or lender outcomes.

CheckFile A: unexplained discrepancyFile B: legitimate variable pay
Payslip recordFortnightly net pay of $3,200Fortnightly net pay of $3,200, including overtime
Bank record for that pay periodSalary credit of $2,400Salary credit of $3,200
Adjacent pay periodAnother $800 difference remains unexplainedNet pay and bank credit both fall to $2,600 when overtime stops
Source responseIndependently contacted payroll confirms $2,400 and cannot confirm the submitted $3,200 recordIndependently contacted payroll confirms both periods and the overtime
Broker actionHold the disputed income, preserve both responses and escalate the conflicting documentRecord the explanation and apply the chosen lender’s variable-income rules

File A needs escalation because the payroll response conflicts with the submitted evidence. Even then, the broker records the conflict without deciding who altered the document. File B supports genuine variable income, although the lender still decides how much overtime it accepts.

Font changes don’t decide either result. The source response and the matching pay-period evidence do.

Verify Through Reliable Channels

Verify the disputed fact through a source whose identity you confirm independently, while keeping the original document unchanged. Start with the exact mismatch, not a general request for the client to prove everything again. Use your licensee’s approved process and the lender’s evidence requirements.

  1. Record the discrepancy. For an income check, note the document and pay period with the conflicting amount. For an identity check, name the detail that differs.
  2. Ask for a factual explanation when your compliance process permits it. Record the client’s account without coaching them to replace or alter evidence.
  3. Obtain corroborating records through an authorised route. Match the dates and account holder, and compare net pay with the relevant bank credits.
  4. Confirm the source contact independently. Use an employer’s official switchboard or an established professional contact, then reach the person authorised to confirm the fact.
  5. Record the response and decide what remains unresolved. Identify the staff member who checked it, the date, the source contact and precisely what that source confirmed.

A telephone number printed on a disputed payslip isn’t an independent employer check. Nor is a new letter from an unverified email address enough to resolve the conflict. Obtain the contact separately and record how you established it.

For File A, the processor calls the employer’s independently located switchboard and is transferred to authorised payroll staff. Payroll confirms the applicant’s employment but confirms net pay of $2,400 for the period. Employment is supported, while the submitted $3,200 pay figure remains unsupported.

The processor saves a dated note of that response and refers the disputed figure to the compliance owner. The application mustn’t continue using $3,200 as verified income. If the file was already lodged, the owner tells the lender which submitted figure is disputed and asks for instructions on the affected application.

Use bank statement analysis to reconcile transaction timing and explain transfers. A deposit description alone doesn’t establish that money is wages, and a legitimate transfer between the client’s accounts mustn’t be counted twice as income.

Once the source records explain the income, you can use Bulma’s Policy Advisor to check the lender’s documentation and variable-income rules. Bulma quotes the policy wording behind each answer, which you can retain in file notes. Keep the separate source verification and its outcome with that policy evidence.

Preserve Originals and Protect Personal Information

Save the received document in its original form and keep the original email or upload record. Store notes and annotations separately, and retain later replacements as separate versions. Restrict access to the people handling the application or reviewing the concern.

Don’t edit a disputed PDF, replace an original with a screenshot or overwrite it when a client sends a corrected version. A correction can help explain an error, but the earlier record still shows what was received and relied on.

The Office of the Australian Information Commissioner (OAIC) explains privacy duties when using commercial AI products. For organisations covered by the Australian Privacy Principles (APPs), APP 6 limits use and disclosure, while APP 11 requires reasonable steps to protect personal information. Use approved systems and send only the information the authorised recipient needs.

Don’t put a client’s complete identity and financial file into an unapproved AI tool to ask whether it is fraudulent. Keep any authorised automated review within your organisation’s privacy controls and have a person assess the evidence.

Escalate and Preserve the Record

Give the unresolved file to the broker or compliance owner named in your licensee’s procedure, with the evidence and the application status. That owner decides the next action and coordinates lender communication. A processor can identify a discrepancy and stop the affected work without declaring that fraud occurred.

Prepare an escalation record that lets the recipient follow what happened.

  • State the application reference, lender and current stage, including any approaching settlement.
  • Identify each disputed fact and the original document that contains it.
  • Include the client’s explanation and the independent source response, with dates and the person who obtained them.
  • List the checks completed, the unresolved points and any income or identity evidence no longer relied on.
  • Record who owns the next decision, what the lender has been told and when a response is due.

Use neutral wording, such as “the payslip shows $3,200 net pay, while payroll confirmed $2,400 for that period”. Avoid “the client forged the payslip” unless an authorised investigation has established that fact. Send original records through the recipient’s approved secure channel, with personal information limited to what the review requires.

If misconduct by someone inside the brokerage is suspected, use the licensee’s alternate escalation or whistleblower route. Don’t leave the review solely with the person whose conduct is questioned. The compliance owner assesses any separate regulatory or police reporting obligation.

Report a CommBank Application Concern

As at October 2026, CommBank’s broker contact page directs application questions to the case owner or assessor listed in “Notes To Broker” in Your Applications. It also lists Broker Assist on 13 25 88, option 1, for brokers and broker delegates. For a suspected document problem, tell the case owner or Broker Assist what is disputed and request referral to the appropriate fraud-review channel.

Prepare the application number, lodgement date and current stage before making contact. Have the disputed original documents, the comparison records and the independent verification note ready. Explain whether the disputed figure has already been used in the application and whether settlement is imminent.

Ask the recipient how to send the evidence securely and obtain a contact or reference for the handoff. Keep the file marked “verification unresolved” until your compliance owner records the outcome. Don’t send the entire client file to an address supplied in a suspicious message.

CommBank’s public scam-reporting route, as at October 2026, is the CommBank app or 13 2221. A client whose account or identity is being misused can use that route alongside the broker’s application escalation. The bank’s hoax mailbox is for suspicious emails or messages, so don’t treat it as a general mortgage-document submission address.

CommBank also lists its Speak Up program for brokers reporting unethical behaviour or corruption. Use that route where the concern involves conduct, and keep the application-risk escalation active through the case owner.

Before resuming the application, obtain the recorded decision on the disputed evidence. If the concern is resolved, retain the corroboration and apply any corrected income figure. If it remains unresolved, follow the compliance owner’s and lender’s instructions, preserving the original file and the reasons for the decision.

Check the policy behind your next scenario

Ask Bulma a lender policy question and inspect the source behind the answer.