C.26 Compliance - Preliminary Assessment
The Preliminary or Written Assessment must be created within 90 days of the credit being completed. However Premium Broker require this document to be created prior to submitting the loan. If the loan is in VowNet it is as simple as creating the document.
Responsible Lending or RG209. Making a preliminary or final assessment will require you to take active steps to form a reasonable view about whether the contract is ‘not unsuitable’ for the consumer. We expect that you will base this assessment on the reasonable inquiries you have made about the consumer:
There are three main issues for you to consider in determining whether a credit contract or consumer lease is ‘not unsuitable:
will the consumer be able to meet their financial obligations under the contract without substantial hardship;
does the contract meet the consumer’s requirements and objectives; and
do any circumstances apply to the contract that have been prescribed
Request from the client We are required to give a free copy of the written assessment to the consumer if they ask you for one within seven years of entering into the credit contract.
Signing the Preliminary Assessment.
When you create the Preliminary it is deemed that you have signed the document at the same time. There is therefore no need to sign the document once it is saved electronically. Whilst ASIC regulations do not specify the Assessment needs to be signed and dated, if the client requires a copy it is common courtesy to sign it.