Writing a credit proposal in Australia starts with knowing which document you are actually producing. For consumer home lending, the credit proposal is the Credit Proposal Disclosure a broker gives when recommending a credit contract, a statutory document under the National Consumer Credit Protection Act 2009 that sits alongside the Credit Guide. For business lending, the proposal is a credit submission to a lender arguing why a facility should be approved.
This guide covers both separately, because they follow different rules: one is compliance-driven with prescribed content, the other persuasion-driven with lender expectations. The purpose classification decides everything, so check it first; a client chasing a personal loan for private costs falls under the consumer regime even when the application feels commercial.
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The consumer Credit Proposal Disclosure
When you recommend a loan to a consumer client, the disclosure document must identify the credit assistance provided, state the commission you or your aggregator receive from the lender and any fees payable by the client, and explain their rights, including details of the internal dispute process and external dispute resolution scheme. It works as a pair with the Credit Guide, which introduces you, your licensee and the general nature of your services.
- Complete the fact find and preliminary assessment before shortlisting products.
- Select the recommended loan and record why it suits the client’s circumstances better than alternatives considered.
- Generate the Credit Proposal Disclosure from your software or licensee template, checking commission and fee figures against current agreements rather than defaults.
- Provide the disclosure together with the Credit Guide before lodging anything, and keep evidence of delivery on file.
The business credit submission
A genuine business-purpose facility usually falls outside the National Credit Code, which changes the document’s character entirely: this is a persuasive case for approval, not a statutory disclosure. Strong submissions share a structure:
- Summary: who is borrowing, how much, for what purpose and the repayment plan in a page.
- Business overview: legal structure, trading history, location, what the business sells, its target market and its marketing strategies.
- Financial position: two to three years of financial statements, current management accounts and realistic projections showing serviceability.
- Purpose and security: exactly what the facility funds and what security supports it.
- Supporting material: BAS records, contracts or letters of intent that substantiate the story.
Write it plainly and quantify everything; lenders approve numbers supported by documents, not adjectives.
Tools that help
Templates speed up both documents: platforms such as BrokerEngine can generate disclosure documents for consumer files, but treat any output as a tool whose contents still need checking against current agreements, not as compliance itself.
The compliance behind either document
A disclosure only means something when it rests on a proper assessment. ASIC’s RG 209 frames the inquiries and preliminary assessment behind every recommendation: make reasonable inquiries into the client’s requirements and objectives, take reasonable steps to verify their financial position, and assess whether the contract is not unsuitable. The Best Interests Duty then requires you to show the recommendation serves the client’s interests, documented in file notes covering the alternatives considered.
Mistakes that sink either document
- Stale figures: using last year’s commission rates or outdated financials instead of current verified data.
- Jargon over clarity: dense language hides whether the borrower genuinely fits the product, which matters in both documents.
- Unsupported claims: assertions about income, serviceability or business prospects without documentation behind them.
- Wrong instrument entirely: sending a marketing-style submission where a prescribed disclosure is required, or vice versa.
For consumer files, presentation also carries a message: clear documents and responsive handling reflect the customer service standard clients use to judge brokers. For business submissions, evidence beats volume; a tight proposal with verified employment history, clean statements and a credible repayment path outperforms a thick folder of padding every time, and lenders will test whatever credit history and liabilities you disclose anyway, so disclose accurately first.
This week, open your last five consumer files and confirm each contains three things: a completed needs analysis, a delivered Credit Proposal Disclosure with the matching Credit Guide, and file notes recording the alternatives considered. Any file missing one of those three is carrying regulatory risk that costs nothing to fix today and everything to fix after a complaint.
