How to Switch Mortgage Aggregator in 2026

To switch mortgage aggregator, work through five stages in order. Confirm what can move, resolve the departure conditions, secure the new arrangement, protect live files and payments, then cut over and check. The order matters because your credit authorisation, lender codes, trail and client records each sit under a different agreement.

A client record that arrives in your new customer relationship management (CRM) system doesn’t give you access to that client’s loan at the lender. Lender access comes from accreditation under the new aggregator, so a file can move while its application stays tied to your old broker code.

This guide is for brokers who have already chosen a replacement and are planning how to change mortgage aggregator. If you’re still comparing operating models and agreements, start with the guide to choosing a mortgage aggregator.

Confirm Feasibility and Scope

Switching aggregator is possible, but most of the move is manual. Client data moves only within the access your departing agreement allows. Don’t assume any lender code carries over, and trail on your existing book moves only if the agreements behind it allow it.

If your aggregator holds the credit licence, you are its credit representative. The Mortgage & Finance Association of Australia (MFAA) says aggregators typically hold the Australian credit licence and appoint brokers as representatives. They also connect brokers to a lender panel and help them meet each lender’s accreditation requirements.

The table shows what each part of the switch depends on. Use it to sort your tasks into what transfers and what you rebuild.

Item	What happens when you switch finance aggregator	What decides it	Manual work
Credit representative authorisation	The new licensee authorises you. Your existing credit representative number stays with you.	National Consumer Credit Protection Act 2009 (NCCP Act), sections 71 and 72	New licensee lodges its notice with the Australian Securities and Investments Commission (ASIC). Old licensee lodges its revocation notice.
Lender accreditation and broker codes	Don’t assume any code carries over. The new aggregator applies to each lender on its panel for you.	Each lender’s accreditation requirements	Apply lender by lender and track every pending code.
Live applications	Each stays recorded against the broker code it was lodged under.	The departing agreement and the lender	Agree in writing who finishes each file.
Trail on the existing book	Stays with the departing arrangement unless its agreements allow a transfer.	Your departing aggregator agreement and its lender agreements	Get a written statement of who pays trail after you leave.
CRM records, file notes and documents	Move only through an export your agreement permits.	Data and record-access terms, plus the Privacy Act 1988	Map fields, then check documents and history arrive intact.
Credit guide	Replaced with one that names the new licensee.	NCCP Act, section 158	Issue the new guide from the first new client contact.

Contract Terms That Can Delay the Switch

Read the departing agreement for terms that can push back your planned cutover date. These clauses can set the timing:

• the notice period and how notice must be given
• a minimum term or an exit fee for leaving early
• restraints on contacting clients, staff or referrers after you leave
• conditions on trail continuing after termination
• your liability for clawbacks on loans that discharge after you leave
• who owns the client database and how long you keep access to it

Exit fees and other leaving costs are covered in the guide to mortgage aggregator fees. The notice period usually sets the earliest cutover date, so read it first.

Build the Handover Register

Create a handover register with one row for every live application before you change anything else. Record the lender, the broker code it was lodged under, the current conditions, the submission history and the person responsible for it after cutover.

You need the register because lender access follows the code, not the CRM. The lender recorded the application against your old broker code, so a copied CRM record doesn’t let you or the new aggregator see or update it at the lender.

The rows below are a hypothetical example.

Client and application	Lender	Broker code	Current conditions	Submission history	Responsible after cutover
Client A, purchase	Lender 1	Old code	Valuation and signed contract outstanding	Lodged 3 March, conditional approval 10 March	You until cutover, then the old aggregator’s settlement team
Client B, refinance	Lender 2	Old code	Payslips requested	Lodged 12 March	You, aiming to finish before cutover
Client C, new enquiry	Not yet chosen	None	Not lodged	Fact find only	You, to lodge under a new code

Add a row whenever a new application starts before cutover. Each row is finished only when the responsible person confirms the outcome in writing.

Read the Departure Conditions

Before you contact any client or export any data, get written answers on notice, restraints and record access. If you contact clients or move data first, you can breach a restraint or an access term that you haven’t yet resolved.

Work through the departure conditions in this order:

1. Confirm the notice period and give notice exactly as the agreement requires. Record the date your notice takes effect.
2. Read every restraint and note what it stops you doing and for how long. Hold any client announcement until you know whether the restraint covers it.
3. Confirm your record access after termination. Ask for the agreed access period, the systems it covers and the export format in writing.
4. Check what your privacy collection notice told clients about who receives their information. Under Australian Privacy Principle 6, the Office of the Australian Information Commissioner’s guidelines (version 1.1, 22 July 2019) allow disclosure for the primary purpose of collection. They also allow it with consent, or where the client would reasonably expect a related use.

Your old licensee keeps a stake in the records too. In Regulatory Guide 273, issued 24 June 2020, ASIC expects licensees to ensure records showing their brokers’ best interests compliance are kept. Expect the departing aggregator to retain copies of files it licensed, and agree how you can reach them later.

Questions for a Qualified Adviser

Ask a lawyer who reviews broker agreements about these points before you give notice:

• whether the restraint can be enforced as written, and what it stops you doing
• whether the agreement gives you a right to trail on loans you settled after you leave
• who carries clawbacks on loans that discharge after termination
• who owns the client relationship and the client data
• whether the departing aggregator can set off unpaid fees against commission it still owes you

An accountant can also tell you how the exit fee and a gap in commission payments affect your cash flow.

Secure the New Arrangement

Give every dependency in the new arrangement a named owner and a target date before you set a cutover day. Your new licensee authorises you, the new aggregator applies for lender accreditations, and you set up systems and client documents.

Under the NCCP Act, compilation dated 1 July 2026, the new licensee must notify ASIC within 15 business days of authorising you. Your old licensee has 10 business days after revoking your authorisation to lodge its own notice. Section 72 stops ASIC issuing a new credit representative number when you already have one.

The schedule below is a fictional example for a broker with a three-month notice period.

Week	Dependency	Owner	Done when
1	Notice given under the departing agreement	You	Written acknowledgement received
2	New aggregator agreement signed after legal review	You and your lawyer	Signed copy held
3	Lender accreditation applications lodged	New aggregator’s accreditation team	Application listed for every lender you use
4 to 10	Broker codes issued	Each lender, chased by the new aggregator	Code recorded against every lender
8	New CRM set up and staff accounts created	You and the new aggregator	Test client record saved and viewed by each staff member
10	New credit guide drafted	You, checked by the new licensee	Guide names the new licensee and your credit representative number
13	New authorisation takes effect	New licensee	ASIC notice lodged within 15 business days
13	Old authorisation revoked	Departing licensee	ASIC revocation notice lodged within 10 business days

Mark any lender without a code by week 10 as a risk. Keep new submissions for that lender under the old arrangement, or delay them, until its code is issued.

While some codes are pending, check new scenarios against the lenders where your accreditation is already live. Bulma’s Scenario Planner checks a client’s scenario against 52+ lenders’ policies and groups them by fit, so you can see which accredited lenders suit the client before you submit.

Separate the Existing Book From New Business

Separate your existing-book commission rights from future submissions before the overlap period starts. Treat settled loans and live applications as the existing book under the old agreement. Treat new applications as future submissions through the new aggregator from cutover.

The MFAA’s broker remuneration factsheet, as at October 2026, says lenders pay upfront commission on settlement and trail monthly for the life of a loan. It also says lenders claw back upfront commission when a loan is discharged within 18 months to two years of settlement.

Confirm in writing which party handles each of these during the overlap:

• reconciling trail on the existing book
• reversals and clawbacks on loans settled before cutover
• upfront commission on live applications that settle after cutover
• unresolved complaints about files arranged under the old licence

The guide to trail commission explains how trail is calculated, and the guide to broker clawbacks covers reversals.

Protect Files and Payments

Before cutover, reconcile every live application and every outstanding commission. Then check that your export keeps client consent, document history and the records you need for later review.

1. Reconcile live applications. Compare the handover register with each lender’s current status and update the conditions and responsible person for every row.
2. Reconcile outstanding commissions. List upfront commission due on loans that have settled, the latest trail statement and any open clawback. The MFAA notes commission can take up to 90 days after settlement to arrive, so include recent settlements.
3. Run a trial export of five complete client files. Check that each one arrives with its documents, file notes, consent records and submission history.
4. Fix any field or document that failed to arrive, then run the full export within your permitted access.

What the Export Must Keep

Your export must keep the records that show how you acted for each client. In RG 273, ASIC expects brokers to keep the credit guide given to the client and the information given to the lender. The same list includes application outcomes, relevant conversations, the options you presented and the reasons for your recommendation.

ASIC says in RG 273 that the retention period depends on the loan term, any interest-only period and whether the client refinances. A short retention period can leave you unable to show how you met the best interests duty.

Check each trial file against this list before you approve the full export:

• the credit guide the client received, with its date
• the client’s privacy consent and any authority to share information
• the fact find and supporting documents
• what you sent to the lender, with dates
• file notes of conversations and the reasons for your recommendation
• the application outcome

Execute, Validate and Recover

On cutover day, check lender access, staff permissions and client communications before you lodge anything new. Then reconcile the first trail statements and keep a recovery route open for anything that failed to transfer.

1. Check lender access. Log in to each lender’s broker channel under the new arrangement. Expected result: every lender in the register shows an active code.
2. Check staff permissions. Have each staff member open a test client record and a document in the new CRM. Expected result: each person sees only the records their role allows.
3. Check your ASIC record. Search ASIC’s professional register for your credit representative number. Expected result: it lists the new licensee once the authorisation notice is processed.
4. Check client communications. Send the new credit guide with your first contact for every new application. Section 158 of the NCCP Act requires your guide to name the licensees you act for.
5. Check the handover register. Expected result: every live application has a named person responsible and a current status.

Reconcile Residual Trail Statements

Compare the first statements from the departing aggregator, and any from the new one, with your settled-loan list. Expected result: each settled loan appears on exactly one statement, under the party your written agreement names.

If a loan appears on neither statement, raise it with the departing aggregator first and quote the agreed trail terms. If it appears on both, tell both parties in writing before either payment is reversed.

Recover a Failed Transfer

Use a staged fallback when a file, code or payment doesn’t transfer. Keep your authorised access to the old records and escalate the open item to the named contact at each aggregator.

Symptom	Check	Recovery step
A client file is missing documents in the new CRM	Compare it with the trial export checklist	Request the missing items through your agreed record access and re-import them
A lender rejects a submission under the new code	Confirm the code is active with the new aggregator’s accreditation team	Hold the submission until the code is active, or lodge with an accredited lender that fits
A live application has no responsible person	Check the register and the departing aggregator’s handover list	Name the owner in writing before the next lender deadline
Trail is missing from both statements	Compare loan numbers with the departing agreement’s trail terms	Escalate to the departing aggregator with the loan list and the clause

Keep the old access only for the period and purpose your termination terms allow. Copying client data outside that access, or ignoring the notice and restraint terms, can create a new breach while you fix the first problem.

Close the switch only when the register, both trail statements and every lender code agree. Until then, keep the departing aggregator’s contact, your agreed access period and the open items list in one place you check each week.