How do we handle – Non-Disclosure Restraining Order: If we receive a request for a restraining order, we do not disclose any information about it to the borrowers and we need to forward the request through to compliance immediately. Flash notes would be placed by for reference

How do we handle – Valuation Report: For borrowers requesting copies of valuation reports, we (the lender) CAN now send a copy of the borrowers' valuation report provided:

*They have paid for the valuation fee

*It is stated in the loan agreement/disbursement schedule that they have paid for it

*They have stated the reason why they want to obtain a copy of it

Our Compliance team has confirmed that there has been a change in the law and National Consumer Credit Code.

How do we handle – Compromised Borrowers: Be mindful of any advice of accounts being compromised, make sure to always take note of the following:

1. Be more vigilant with your ID process of customers moving forward that have experienced this issue / Extra security questions

2. Disables redraw facilities

3. Ask borrowers to monitor/review the transactions on their accounts

4. Refer to us again, if there are any suspicious transactions, they wish to flag

5. Inform all CS staff of this issue and process

In addition, we need to ask the customers to change the password on their login accounts.

We also need to have it lodged on the incident report via SharePoint, as an incident and not a data breach as it was not a Columbus Capital breach.

How do we handle – Disabling Redraw of Offset due to Marital Dispute: We must make sure moving forward that:

1. When a customer requests that redraw on a loan is switched off that we honour that, and we cannot allow redraw on a loan.

2. With respect of offset accounts, it is more in the grey area as to whether we can restrict the funds where there are joint borrowers as we could be adversely impacting the other

   party by not giving them access to monies held in the offset account so this needs to be escalated to Compliance for guidance on a case-by-case basis.

   Regarding with this update are as follows:

    

   1. We must disable redraw on the loan and do not approve it unless both borrowers request and sign in writing and we verbally confirm that it is their signature and a genuine request.

       

   2. We cannot restrict offset because it is their money, and we are disadvantaging the other

      borrower. If the wife wants to protect the money in the offset, then she should put it in the loan, and we will leave it in the loan, but we will not allow redraw unless everything is satisfied as per point (a) above. –

      How do we handle – Solicitor Request in Creating Probate: We may proceed to provide the requested information to the solicitors, when we receive this kind of request form a solicitor who advise that they are acting for the Estate or to do a probate. We can release the information provided by these solicitors with sufficient evidence. We need to make sure they have submitted first at least a copy of will/ death certificate along with a formal letter of the request with letterhead of solicitor company.

      How do we handle – Insurance Company Enquiries: Please note that we do not offer any of the products listed below nor are our borrowers charged for the following products:

      • Consumer Credit Insurance / Loan Protection Insurance / Credit Card Insurance / Mortgage Protection Insurance / Shoppers or Buyers Protection

      • Guaranteed Asset Protection / Shortfall Insurance / Motor Equity Insurance / Total Asset Assist

      • Mechanical Breakdown Insurance / Extended Warranty

      • Small Damage Repair / Tyre and Rim

      • Others

        Please note that we only provide loan products and NOT any insurance products so there is no relevant information for us to provide you with.

        How do we handle – Call Recordings/Transcripts: Under Privacy Laws we must provide a copy of the call recordings if requested.

        However, it does come down to a case-by-case basis and the context for the request. E.g., If it is a marital issue and the Mr is requesting Mrs. call recording – No.

        How do we handle – Updating Primary Mailing Address: If you receive a scenario where a borrower/mortgage manager/broker requests to have the accountant’s office address listed to receive correspondence for audit and tax purposes (mostly for SMSF on what we observed),

        please take note of the following:

      • We cannot use the accountant’s address as primary postal for the primary or the guarantors.

      • We have a legal obligation to provide borrowers with a copy of their statements bi- annually and it is up to the borrower to whom they would want to provide the copy too.

        The accountant is still considered an unregistered 3rd party. In the event they complete a third party form the statements would still be sent through to our borrowers only.

        How do we handle – Recall of Funds Due to Fraud: Please be advised that as per Compliance, each time we receive a request for a recall of funds from a customer due to fraud, we need to copy it into our Compliance team when we send a recall request to Treasury.

        Kindly see update and process improvements below that we need to remember when handling these types of requests as advised by Compliance:

      • All” Fraud” based recalls are to be actioned ASAP same day, once requested.

      • These accounts are to be considered urgently, and priority is to be placed on these accounts, where a customer has brought it to our attention – money has already left the customer’s account.

      • CC Compliance Team in the 1st email, along with Treasury

      • We do not need to wait for Treasury to investigate the account and respond before the recall is carried out.

Treasury is to provide report investigation by email as per below once done.

Good to Know – Direct Debit Form Policy: Direct Debit form needs to be completed and signed by ALL borrowers. The email must be from the registered e-mail address, confirming the new $ amount.

DO NOT CHANGE details without receiving a completely SIGNED Direct Debit form.

Good to Know – Third Party Access/Authority to Act:

1. Registered Power of Attorney –

    

   1. FULL ACCESS: For the TPA POA to access the Loan to Act, Provide and Obtain All Information on the Borrowers’ behalf.

      1. Access To – Deposit funds, transfer funds between our accounts (Loan to Offset vice versa), arrange or change payments, pays bills, transfer to external parties, notify of bankruptcy (proof required), court order or death of a customer (proof required), in addition to enquiry access.

      2. NO REDRAW ACCESS AT ALL ON LOAN ACCOUNT (we do not want the debt/loan balance liability to increase), Offset Redraw is a case-by-case basis.

      3. POA is only if a customer is unable to manage their own financial affairs (e.g., Physical or Mental limitations of the customer)

      4. Required Documents: Register Power of Attorney (signed by Solicitor/Lawyer, Borrower & POA), TPA form & ID – Docs must be saved on Coral.

       

2. Accountants / Financial Planners / Solicitors / Lawyers / Brokers / Family / Friends –

    

   1. ENQUIRY/VIEW ACCESS ONLY: TPA can only obtain information. They have no authority to provide or change any details of the Loan.

   2. Access To – obtain Statements, obtain balances and information surrounding payment details, credit limits, interest rates and transaction details.

   3. Required Documents: TPA form & ID – Docs must be saved on Coral.

       

3. SMSF Loans

    

   1. ENQUIRY/VIEW ACCESS ONLY: Unless there is a Registered Power of Attorney

   2. The above rules apply, even in the case of a Borrower wishing their Accountant to direct funds on their behalf, for Investment Opportunities in and out of the SMSF Offset Account, plus paying the SMSF property-related bills etc.

In the best interest of our Borrowers, we must always remain vigilant with regards to their privacy.

How do we handle – Sending a Loan Agreement and Security Packet: Customers are only to be provided “SIGNED COPIES” of their Loan Agreements/Documents if they have requested a copy of them.