What can mortgage support staff do under a credit licence?

What can mortgage support staff do under a credit licence? The answer follows the actual task, the person performing it and the authority they have, rather than the title on a job advertisement. Collecting a document, explaining a lender condition and suggesting a particular loan can look close together in a busy inbox, but they create different questions for a licensee. Use this article as a workflow design aid, then have your licensee or qualified compliance adviser assess the real duties before work begins.

Start with the activity, not the job title

ASIC's credit licensing guidance says credit activity can include suggesting or assisting with a particular credit contract and acting as an intermediary between a credit provider and a consumer. It also describes possible paths for a credit representative, an employee or director of a licensee or related body corporate, and certain exemptions. These paths have conditions. “Loan processor”, “assistant”, “virtual assistant” and “offshore support” are not legal answers on their own.

Map the whole action. A worker may only enter facts from a broker-approved note, or may effectively choose the product and communicate that choice. A message drafted by one person and approved by another still needs a clear record of who decided the content and who sent it. Also identify whether the worker is employed by the licensee, a related body corporate or a separate supplier. Do not assume that a supplier's employee is the licensee's employee merely because they use the licensee's CRM.

Use a task matrix before delegation

The following matrix is an operational prompt, not a ruling that any row is always permitted or prohibited. “Pause for review” means the licensee decides the legal classification, authority, supervision and customer communication path for that specific work.

Example task	Possible preparation	Decision or approval point
Receive requested documents	Log receipt, check legibility and note missing items against an approved list	Broker or authorised reviewer resolves inconsistent evidence and decides sufficiency
Populate a file	Enter factual fields from identified sources under a broker instruction	Reviewer checks discrepancies and approves the next file stage
Answer a status question	Use an approved factual status, channel and escalation script	Pause if the response implies a credit recommendation or changes a promise
Compare loan choices for a customer	Gather questions and source material for the broker	Authorised person assesses and communicates any particular-contract suggestion
Contact lender or submit a pack	Prepare factual items only within approved system permissions	Licensee decides whether the contact or intermediary step is credit activity and who may release it
Handle a complaint or changed circumstances	Record the issue accurately and flag its urgency	Named broker or complaints owner takes the substantive response

For each row, write the named preparer, reviewer, approved channel, file evidence and escalation trigger. The broker-to-processor handoff guide gives a compact way to record these decisions per file. A good matrix lets a new worker say “I can collect the missing page; I cannot decide which income figure to use.”

Check the employment and authorisation route

ASIC explains that a person undertaking credit activity will generally need a credit licence or an available authorisation or exemption. An appropriately authorised credit representative and an employee or director of a licensee or related body corporate may have different routes under the regime. The exact facts matter, including whose activity the worker performs and whether an exemption's conditions are met. A contractor arrangement should be reviewed before the contractor performs a task that might be credit activity.

ASIC's RG 205 says a credit licensee can outsource functions connected with credit activity but remains responsible for meeting its obligations. It also says third parties undertaking credit activities on the licensee's behalf will generally need to be a credit representative or a licensee. That makes the provider agreement, scope of work, training and monitoring relevant; none is a substitute for the required legal authority.

Have the licensee answer four questions in writing before turning on a task: What exactly will the person do? Whose employee or representative are they? What authority or exemption, if any, covers that action? Who reviews their work and handles exceptions? Keep the answer with the role brief, then revisit it whenever the tasks change.

Make the customer-facing boundary usable

Write a short script for common questions. If a customer asks, “Which of these loans should I take?”, the support worker can acknowledge the question, record it and route it to the broker or appropriately authorised person. They should not improvise a product comparison to be helpful. If a customer asks whether a document arrived, a factual answer may fit an approved administrative workflow, but the script should still define what to do when the question turns to suitability, pricing or approval chances.

ASIC's RG 273 explains the best interests duty for mortgage brokers who provide credit assistance. A processor's tidy file does not transfer the broker's judgment. Keep a visible trail of the customer's question, the broker's decision, the approved message and the person who sent it. Review a sample of real conversations during onboarding to catch a script that is quietly drifting into recommendations.

Consider data access alongside credit authority

Permission to perform a task and permission to see borrower data are separate decisions. Give access to assigned files and actions only, using individual accounts and a defined removal process. If a worker is overseas, map which entity receives the personal information and how the arrangement works. The OAIC's APP 8 guidance says providing personal information to an overseas contractor is a disclosure in most circumstances for an entity covered by the Australian Privacy Principles; the facts and exceptions need review. Location alone does not answer the credit-licensing question.

Our offshore support checklist covers the broader provider, access and review plan. If the job combines enquiries and file preparation, use the assistant-versus-processor comparison to separate the queues before assigning authority.

Review the boundary as work changes

At the end of the first month, inspect a sample of file notes, customer messages, lender contact and blocked cases. Ask whether each action stayed inside the written scope, whether the reviewer actually checked it, and whether any task should move to a different person. Update the role matrix when a new lender portal, product workflow or service provider changes the work. A written boundary is useful only if the systems, training and daily queue follow it.

This framework helps a brokerage ask the right operational questions. The final position for a particular person and activity belongs with the licensee's legal and compliance assessment, supported by a task list specific enough to review.