People First Bank lending policy applies to new broker business, while existing Heritage and People’s Choice loans need their original facility and commission records carried forward. The loan event determines the pay question: new lending, extra funds, a product switch or a discharge. A change of brand alone does not identify that event.
Heritage has closed new broker applications and new accreditations. Existing Heritage borrowers can still request top-ups through their broker. People First Bank takes new business through its own broker channel.
Upfront Commission and Trail Balances
For a People First Bank settlement, separate the amount eligible for upfront commission from the balance used for ongoing trail. Record the lender’s payment basis against the facility, then apply your aggregator’s split and GST treatment separately. An approved credit limit and an amount actually borrowed are different figures.
For covered residential lending, the National Consumer Credit Protection Regulations 2010 link percentage-based upfront remuneration to a drawdown cap. Regulation 28VD calculates maximum drawdown net of offset from actual debt and offset balances. Regulation 28VC sets the scope and exceptions. This legal cap does not set People First Bank’s commission rate. Read the remuneration regulations.
Keep the offset balance separate from available redraw and undrawn credit. Redraw is access to repayments already made. An undrawn limit is credit the customer has not borrowed. Apply each adjustment only in the way the facility’s remuneration terms require, including the balance measurement period for trail.
The AFG commission summary has separate Heritage and Peoples Choice rows with different trail progressions. Keep those identities separate when preparing an expected-payment calculation. That table is not a People First Bank migration instruction or a replacement for the agreement governing the loan.
Clawbacks and Refinance Events
Classify a refinance by the debt being repaid and the replacement contract, including the lender’s treatment of a transfer between its brands. People First Bank is a trading name of Heritage and People’s Choice Ltd. Moving from Heritage to People First Bank therefore needs the internal-transfer classification recorded explicitly.
An external refinance replaces debt held with another lender. On the outgoing loan, a full discharge ends the balance supporting future trail and can trigger recovery of upfront commission. On the incoming loan, remuneration follows the replacement lender’s eligible-settlement terms. An internal product switch does not establish a fresh entitlement to upfront on retained debt.
Regulation 28VG limits covered clawback obligations to two years and caps recovery at the benefit paid. Its start rule distinguishes refinance credit from other credit. The customer cannot be required to pay because the broker’s benefit is clawed back. Use the contractual recovery period and tier within those legal limits.
A partial repayment leaves a facility open and can reduce its trail balance. Apply a partial-repayment recovery clause only when the governing agreement includes that event. Keep the repayment amount and the remaining debt beside the clause used to calculate any recovery.
Top-Ups and Split Restructures
Separate additional borrowing from debt retained inside the bank before calculating remuneration on a top-up. A new split number can hold old debt, extra funds or both. The split number alone cannot identify new money.
In a hypothetical example, a borrower retains $400,000 and receives $50,000 more. The resulting $450,000 balance contains $50,000 of additional funds. Moving that balance into two replacement splits does not turn the retained $400,000 into extra borrowing. Record the actual release of the $50,000 and apply the event definition in the remuneration agreement.
People First Bank describes top-ups, splits and product switches among its existing-customer loan options. Keep credit approval for the change separate from payment eligibility. A switch can be executable without creating a new upfront payment.
For retained Heritage facilities, the Broker Loan Structure Guide distinguishes one application with splits from separate applications. Same-person loans approved together can sit in one application. Different borrower names or approval timings can require separate applications. Preserve the debt history across either structure.
Legacy Heritage Facilities
Heritage continues to support existing-customer top-ups and applications already in its pipeline through settlement and post-settlement servicing. Its broker transition notice closes new applications and accreditations while retaining that existing-customer route.
Keep each Heritage loan’s original commission agreement and settlement history with its continuing trail record. Apply a later replacement schedule only to the facilities and events covered by the written change. A People First Bank name on correspondence does not establish which trail tier pays an older Heritage account.
For a Heritage top-up, identify the old balance and the added advance separately. For a move to a People First Bank product, record whether the original contract continues or is discharged and replaced. The documented treatment determines whether existing trail continues, changes or ends. It also determines whether a recovery provision applies.
Use the Heritage and People First Bank broker access guide for submission support. Keep the facility’s remuneration decision with the loan file.
People’s Choice Loans
People’s Choice and Heritage merged in 2023 to form the bank now trading as People First Bank. New People First Bank broker applications use Simpology, with DocuSign for signing, according to the bank’s broker information.
An existing People’s Choice loan needs its own trail agreement and payment history. Keep the Peoples Choice schedule identity attached to that record until a written transfer instruction changes it. The separate AFG rows distinguish the legacy brands but do not establish that every loan moves to one remuneration schedule.
The retained Heritage top-up route specifically concerns Heritage customers. For an existing People’s Choice variation, lodge under the route assigned to that facility by People First Bank. Preserve the account’s brand and contract identity in the request so it is assessed against the correct existing debt.
Income and Borrower Eligibility
People First Bank’s application requirements cover identity, Australian citizenship or permanent residency and the applicant’s financial position. Its published starting questions include being at least 18 and accepting a credit check.
For employment income, the bank lists the two most recent payslips or a current Centrelink income statement. It also requests the last financial year’s group certificate or tax return and the last three bank statements. For self-employed applicants, it lists the accountant’s details, two years of financial statements and a tax return.
Support rent with a lease or statements showing receipts. Disclose assets and existing debts. The checklist specifies original documents or certified copies.
Use those documents to explain how the proposed repayment fits the applicant’s actual income and commitments. Where variable earnings or a business adjustment affects the result, show the amount used and the supporting evidence in the credit submission.
Security and Purpose Changes
An unchanged property address does not establish that a proposed increase has the same credit risk as the existing loan. Compare the total proposed debt with the accepted security value to calculate the loan-to-value ratio (LVR). State the current occupancy and the purpose of each additional advance.
A new property or a release of existing security changes what supports repayment. Provide the proposed security allocation for each facility and identify any valuation or mortgage work still required. Heritage’s structure guide instructs brokers seeking separate securities to make that allocation explicit in the application notes.
Support extra funds with documents matching their use. For a purchase, attach the contract. For building work, the bank’s checklist identifies the signed building contract, home warranty and building permit or approved plans. For debt consolidation, show the liabilities being repaid and how those payouts reconcile to the additional borrowing.
Approval Documents and Exceptions
Treat a variation as ready to execute when its written approval covers the final borrowers, facilities and security. Complete all pre-execution conditions first. Read the approval against the submitted structure before arranging signatures.
Keep outstanding items in the file until each has an outcome. These can include income clarification, valuation acceptance, discharge figures and an approved purpose for cash released. Where credit grants an exception, retain the written decision and its conditions with the final approval.
A support conversation about a possible structure does not replace that decision. If an approval leaves the treatment of retained debt unclear, obtain written credit clarification identifying the account and the permitted change. Record commission treatment separately so an accepted credit exception is not mistaken for a payment promise.
Reconciling the Settled Structure
Match every settled facility to the event documented before execution. Map the previous account references to the replacement splits, then reconcile retained debt and new funds against the settlement disbursements.
For a continuing loan, compare the expected trail basis with the next statement. For a replacement, identify the outgoing account’s final payment and the incoming account’s first eligible payment. Keep a brand rename distinct from a genuine discharge when investigating a missing row.
Raise an enquiry when the statement pays against the wrong legacy brand or omits a continuing facility. Other enquiry triggers include upfront calculated on retained debt contrary to the agreement, a recovery under the wrong event or tier and a replacement account that duplicates existing trail. Attach the account mapping and calculation with the governing terms.
Use the monthly trail reconciliation guide to investigate statement differences across your book. For another lender’s rules, use the lender policy guides. Close the People First Bank file when the final structure and its payment record explain the same lending event.
