Read what the client sends
Pull the fields out of payslips, statements and identity documents, match them to the right client file and list what is still missing.
What AI could run / mortgage broking
Let AI prepare the loan file. You make the recommendation.
Document reading, checklist matching and file notes can run through connected AI agents inside the systems a broker already uses. The broker reviews the facts, decides the recommendation and signs the note. ASIC's guidance puts that decision, and the record behind it, with the broker.
Discuss your businessPotential implementation areas
Define the work.
Keep the decision.
Check against your checklist
Line the facts up against a checklist your firm or aggregator sets, and flag anything that does not match.
Draft the file note
Set out the facts the broker recorded in a draft note. The reasons for the recommendation stay with the broker.
Example / not a live deployment
AI prepares.
A person decides.
Illustrative example
Client told and consents → Agent reads and checks → Agent drafts the note → Broker reviews and decides → Broker signs → Record kept
The agent does not recommend a loan or assess suitability. The broker decides the recommendation and writes the reasons.
What the rules say
What ASIC and the Credit Act say
A mortgage broker must act in the best interests of the consumer when giving credit assistance. A licensee must also take reasonable steps to make sure its credit representatives do the same.
National Consumer Credit Protection Act 2009, ss 158LA and 158LEWhere a broker knows or reasonably ought to know of a conflict of interest, the consumer's interests come first.
National Consumer Credit Protection Act 2009, ss 158LB and 158LFASIC says there is no safe harbour. The duty cannot be avoided by a notice, a disclaimer or the consumer's consent.
ASIC RG 273, paragraphs 273.13 and 273.14The consumer decides whether to accept a recommendation. ASIC says it is the broker's sole responsibility to make sure the recommendation is in the consumer's best interests.
ASIC RG 273, paragraph 273.18ASIC expects evidence of compliance to come mostly from the broker's records. It expects them to show the inquiries made, the options and the final recommendation with the reasons for it.
ASIC RG 273, paragraphs 273.21, 273.162 and 273.165Records can be file notes, correspondence, working papers, comparison tool outputs and fact-finds. Notes taken as the work goes may capture a broker's reasoning better than notes written at the end.
ASIC RG 273, paragraphs 273.167 and 273.169Recommending a higher-cost loan needs evidence showing why it is in the consumer's best interests. ASIC's 2026 review found brokers at risk where recorded reasons were generic or missing.
ASIC RG 273, paragraph 273.54; ASIC REP 840, p. 9ASIC says outputs from decision tools or AI agents should be explainable and documented, including the data used. Brokers and licensees remain responsible for the quality of their credit assistance whatever technology they use.
ASIC REP 840, October 2026, p. 28The OAIC recommends against entering personal information, especially sensitive information, into publicly available generative AI tools, and says privacy policies and collection notices should explain how AI is used.
OAIC, guidance on privacy and commercially available AI products (APP 6, APP 1 and 5)
This page summarises ASIC guidance and the Credit Act. It is not legal or compliance advice, and no regulator has approved or endorsed a Numaya setup. Read the sources and take your own advice.
Questions mortgage brokers ask
Clarity before commitment.
Can AI recommend a loan?
Not on this page. The best interests duty sits with the broker, and ASIC says it is the broker's sole responsibility to make sure a recommendation is in the consumer's best interests. An agent can prepare facts and a draft note for the broker to review.
Does using an AI tool change who is responsible?
No. ASIC's October 2026 report says brokers and licensees remain responsible for the quality of the credit assistance they provide, regardless of the technology they use.
What does ASIC expect to see on a file?
Records that show how the broker acted. ASIC's list includes the inquiries made, the options and recommendation with reasons, relevant conversations and any conflict identified. The guidance says records can be file notes, correspondence and comparison tool outputs.
What about client privacy?
The Privacy Act covers personal information entered into an AI tool and any output that contains it. The OAIC recommends against putting personal information into publicly available generative AI tools and says to check what a vendor can do with the data entered.
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