The MFAA has recently updated its NCCP Disclosure Module guidance and templates for brokers in both short and long versions.
These documents provide information about disclosures for finance brokers, and also provide templates that can be used with customers.
This is predominantly in response to changes in expectations about broker disclosures following recommendations after ASIC’s 2017 review of broker remuneration more recently considered by the Combined Industry Forum (CIF).
These focus on changes to broker credit guides to include disclosure of the lenders to which a broker’s business is directed, broker business relationships that involve external ownership and updating documentation to include the external dispute scheme, the Australian Financial Complaints Authority (AFCA). Other disclosure includes a clear assertion of whether the broker has a tiered servicing arrangement with any particular lender.
The MFAA suggests that you familiarise yourself with these updates and accordingly update any of the customer disclosure materials your business is using, in order to remain compliant – subject to any appropriate direction from your licensee who may have already incorporated these changes into your disclosure documentation.
You (MFAA members only) can access this guidance here.
If you have any questions or are in need of assistance, please email the MFAA compliance team at firstname.lastname@example.org.