Effective Date: 15/08/2025
Review Date: 01/01/202
1. Purpose
The purpose of this policy is to ensure that all loans provided by Moneybuddy are:
- Compliant with all applicable Australian laws and regulations, including the NCCP Act, the ASIC Regulatory Guide 209, and Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) obligations.
- Provided responsibly, ethically, and in a manner that protects both the borrower and the business.
Assessed in line with our commitment to responsible lending practices and risk management.
2. Scope
This policy applies to all personal loans issued by Moneybuddy ranging from $500 to $5,000 to individuals who are residents of Australia.
3. Regulatory Compliance
All lending activities will comply with:
- National Consumer Credit Protection Act 2009 (NCCP Act)
- ASIC Regulatory Guide 209 (Responsible Lending Conduct)
- Australian Consumer Law (ACL)
- Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (AML/CTF)
- Privacy Act 1988 (including the Australian Privacy Principles)
- Any other applicable Commonwealth, State, or Territory laws.
Loan Products Covered
- Loan Amounts: $500 – $5,000
- Loan Terms: 3 – 24 months
- Interest Rate / Fees: In compliance with state and federal caps on Small Amount Credit Contracts (SACC) and Medium Amount Credit Contracts (MACC).
- Repayment Frequency: Weekly and fortnightly only repayments
- Loan Purpose: Personal use only (e.g., emergencies, home improvements, personal expenses).
5. Eligibility Criteria
Applicants must:
- Be at least 18 years old.
- Be an Australian citizen, permanent resident, or hold a visa with eligibility to remain in Australia for the loan term.
- Have a regular and verifiable source of income and earn over $500 pw
- Centrelink income can be included, except for job seeker.
- Not be bankrupt or in a Part IX or Part X debt agreement.
- No unpaid financial defaults
- Current telco default will be considered
- Current Part IX’s must provide 24 months good repayment history to be considered
- More than 2 current SACC loans at time of application
- More than 1 pay advance in an applicant's current pay cycle at the time of application
- Gambling and online gaming cannot exceed 20% of client monthly net income.
- No more than 6 Dishonors on the bankstatements
6. Application & Assessment Process
6.1 Application Requirements
Applicants must provide:
- Proof of identity (government-issued photo ID).
- Proof of income (bank statements for last 90 days).
- Proof of address (utility bill or lease agreement).
- Employment details (if applicable).
6.2 Responsible Lending Checks
- Verify Identity under AML/CTF rules.
- Obtain and review bank statements (90 days) using secure electronic verification.
- Assess income and expenses to determine ability to repay without substantial hardship.
- Check credit history via an approved credit reporting body.
- Assess existing debt obligations including SACCs, MACCs, and other loans.
7. Affordability & Suitability Test
A loan will only be approved if:
- The borrower can make repayments without missing other essential living expenses.
- The loan purpose is not for illegal activity or debt repayment from gambling.
- The borrower is not in default with another credit provider for similar products.
8. Loan Approval & Limits
- Initial loans may be capped at $2,500 for new customers.
- Repeat customers with a positive repayment history may access up to $5,000.
- Lending limits and terms will be based on affordability, repayment history, and risk assessment.
9. Disbursement
- Funds will only be disbursed to a verified Australian bank account in the borrower’s name.
- No cash payments will be made.
10. Collections & Hardship
- All collection activities will be conducted in compliance with ASIC and ACCC debt collection guidelines.
- Borrowers experiencing difficulty will be offered a hardship variation in line with the NCCP Act.
11. Privacy & Data Protection
- All personal information will be collected, stored, and handled in accordance with the Privacy Act 1988 and Australian Privacy Principles.
- Customer data will be protected with secure digital storage and encryption.
12. Review & Monitoring
- Loan portfolio performance will be reviewed quarterly.
- This policy will be reviewed annually or sooner if there are changes in law or regulation.
13. Staff Training
- All staff involved in lending will be trained in responsible lending obligations, AML/CTF compliance, and privacy requirements.
- Training will be refreshed annually.
14. Breach of Policy
Any breach of this policy may result in disciplinary action, up to and including termination of employment or cancellation of credit licence.