An offshore assistant can do the file work around a loan: collecting and chasing documents, building the application, ordering the valuation, clearing conditions and coordinating settlement. What they cannot do is the advice — which lender, which product, and whether the loan suits the client. That decision, and the written assessment behind it, stays with the licensed broker and has to be visible in the file. Australia's credit rules turn on who makes the call, not which country that person sits in.
Brokers put the question like this: if I hire someone offshore to process my loans, am I handing licensed work to an unlicensed person? No, provided the line falls in the right place. A processing assistant can assemble the file, collect and chase supporting documents, populate the aggregator CRM and prepare the numbers you asked for. Credit assistance, and the preliminary assessment sitting behind it, belong to the licence holder or the appointed credit representative and do not move.
That sounds tidy on a page. On a live file it is subtler, because the pressure to cross the line comes from clients asking direct questions of whoever answers the phone.
Where the NCCP draws the line
Credit activity in Australia is licensed. Under the National Consumer Credit Protection Act 2009 (Cth), a business engaging in credit activities needs an Australian credit licence or operates as an appointed credit representative of a licensee. ASIC administers the regime, and its Regulatory Guide 203 sets out who needs a licence.
The regulated act that matters most in a broking business is credit assistance. The Act defines it to include suggesting a consumer apply for a particular credit contract with a particular credit provider, or assisting a consumer to apply for one. That is the broker's job, and the licence exists because of it.
Nothing in that definition turns on geography. The Act is not interested in where a person sits; it is interested in who performs the regulated act. It is the same principle that governs a registered tax agent lodging a return, and we map it across every regulated industry we work in on what you can't delegate offshore in Australia.
The practical consequence is a structure, not a rule of thumb. Build the role as preparation flowing into a reviewing credit representative. The assistant prepares; the credit representative decides; the decision is recorded as theirs. Your licensee may also have its own position on offshore contractors, separate from anything in the Act, and that position binds you too.
What the processing assistant actually does
Follow a file from first appointment to settlement and most of it is a document chase with a loan attached. Very little of that work touches the licence.
- Document collection and chasing. Working the lender's supporting document checklist item by item, then re-requesting anything that has gone stale before the file is submitted.
- File setup and fact find entry. Opening the deal in Mercury Nexus, Salestrekker or BrokerEngine, keying the fact find, living expenses and liabilities, and setting the task list so the file matches the aggregator's compliance checklist.
- Lodgement pack assembly. Building the submission in ApplyOnline with documents named and split to the lender's convention, and clearing validation errors so the file does not bounce.
- Valuations and conditions. Ordering the valuation, supplying the assessor with what they have asked for, and working the outstanding conditions list daily.
- Settlement and post-settlement admin. Discharge authorities, signing instructions for the broker to take the client through, certificates of currency, and dates confirmed with all parties.
That list is the loan processor role in one breath. The narrower post-approval version is a settlements coordinator; the wider version, which also covers pipeline and client comms, is a broker support officer.
The servicing table is the sharpest edge
Serviceability is where an otherwise clear boundary gets thin.
An assistant can run the client's income and commitments through Quickli or individual lender calculators, note the assessment rate, the HEM benchmark position and any shading applied to rental, overtime or bonus income, and produce the servicing table you asked for. They can flag where a lender's policy would knock the deal out, because that is a factual reading of published policy.
What the table cannot do is leave your desk. Which lender to approach, which product, and what the client is told about any of it is the credit representative's call. The moment a comparison becomes a suggestion, you are in credit assistance, and it does not matter that the suggestion was made helpfully, informally, or in a chat message rather than a meeting.
The working test we give teams is simple. If a sentence going to the client contains a recommendation, a rate, or the word "should", it is yours to say.
The preliminary assessment and the best interests duty stay with you
Before providing credit assistance, a credit assistance provider must make reasonable inquiries into the consumer's requirements, objectives and financial situation, take reasonable steps to verify that situation, and assess whether the contract is not unsuitable. That obligation sits in the responsible lending provisions of the NCCP Act, and ASIC's Regulatory Guide 209 sets out how it expects the assessment to be approached.
An assistant gathers the verification evidence, records income and expenses accurately and builds the servicing table the assessment draws on. You make the assessment and you sign it. It goes to the consumer only if the consumer asks for it.
Mortgage brokers also carry a best interests duty under Part 3-5A of the NCCP Act, with ASIC's expectations in Regulatory Guide 273, and must give priority to the consumer's interests where a conflict exists. A duty of that kind attaches to the person who owes it. It cannot be delegated to a support contractor, and no amount of supervision changes that.
The document trail around all this is administrative and does travel. Preparing the credit guide and the credit proposal disclosure from your file notes and the aggregator template, recording the date each was given to the consumer, and filing the copies so the sequence still stands up at audit is exactly what a compliance administrator does. Preparing the document is administration. Making the assessment the document reports is not.
Client contact, credentials and client data
Client contact is not all or nothing. Chasing documents and giving scheduled status updates is the highest-value thing a processing assistant does, and clients generally appreciate the responsiveness. Questions about rate, product, structure, borrowing capacity or whether to proceed go back to you, and the answer reaches the client from you.
Give the assistant a script for the handoff so it sounds like process rather than evasion. "That one is for your broker, I will have them call you today" is a complete answer, and better than a well-meaning approximation.
System access is a contract question rather than a legislative one, and it catches people out. Lender accreditation is personal to the accredited broker. Support access to ApplyOnline, the aggregator CRM and lender portals is arranged under the aggregator's own user arrangements, with a separate named login and its own audit trail. Sharing your own login is not a shortcut. Read your accreditation and aggregator terms before anyone touches a portal, because that is where the restriction lives and the wording varies.
Client data carries its own obligations. Payslips, transaction statements and identity documents are personal information, and credit information and credit reporting information attract additional rules under Part IIIA of the Privacy Act 1988 (Cth). Where personal information is disclosed to an overseas recipient, Australian Privacy Principle 8 keeps the disclosing entity accountable for it. Whether a particular arrangement is a disclosure or a use within your own systems turns on the detail of how access is set up, so this is one to work through with your licensee rather than assume.
Ask your aggregator and licensee before you hire, not after. Outsourcing, data handling and system access rules vary between them, and some require notification or approval. An email costs you a day. Finding out after someone already has portal access costs considerably more.
How to set the role up so the line holds
Write the scope down before day one. One page: what the assistant does, what always comes back to the credit representative, and the exact wording they use to hand a question back. Vague scopes are how good people drift over lines nobody drew.
Sequence the handover by how little product knowledge each task needs. Document collection in week one, application assembly with you reviewing every file before submission through the first month, then submission and lender follow-up once they know your panel. That order is set out in full in what a mortgage broker should delegate first.
Then make the boundary visible in the file rather than only in the induction. Assessments logged under the credit representative's name, file notes that show who did what, and a sample of files checked each month. If an audit cannot see the line in the file, the line may as well not exist.
What to do next
Send one email to your aggregator or licensee asking what their outsourcing and system access policy requires. While you wait, write the one-page scope and pick the first task, which is almost always document collection.
If you want to talk it through against your own file flow and your licensee's rules, book a discovery call. We hire the person in the Philippines, they work inside your systems as their own named user, and the credit licence stays exactly where it is. You can see the wider set of broking roles on our mortgage and finance page.
This is general information, not legal or financial advice. Check your own obligations with your licensee, your aggregator or your own adviser.
How we would staff a broking file without touching the licence
We hire a loan processor in the Philippines on your behalf, on your brief, working inside your aggregator CRM and lender portals as their own named user under your aggregator's rules. They carry the file from fact find to settlement and hand you the servicing table; you keep the assessment, the recommendation and the signature. From A$14 an hour plus GST for a full-time dedicated team member, no placement or setup fee, an initial three month contract then month to month, and about two weeks from brief to first day.
- Works the lender's supporting document checklist item by item, re-requests anything that has gone stale before the file is submitted, and gives clients scheduled status updates with an agreed line for handing rate, product or suitability questions straight back to you
- Opens the deal in Mercury Nexus, Salestrekker or BrokerEngine, keys the fact find, living expenses and liabilities, and sets the task list against your aggregator's compliance checklist
- Builds the ApplyOnline submission with documents named and split to the lender's convention, clears the validation errors, then orders the valuation and works the conditions list daily to unconditional
- Runs income and commitments through Quickli or lender calculators and gives you a servicing table with the assessment rate, HEM position and any shading on rental, overtime or bonus income noted — and stops there
- Prepares the credit guide and credit proposal disclosure from your file notes, records the date each was given to the consumer and files the copies in order, then runs the settlement admin: discharge authorities, certificates of currency, signing instructions for you to take the client through, and dates confirmed with all parties
- Credit assistance: which lender, which product, and anything said to a client that amounts to a recommendation
- The preliminary assessment — your inquiries, your verification, your call that the contract is not unsuitable, your signature, logged under the credit representative's name
- The best interests duty, which attaches to you and no amount of supervision moves
- Licensee and aggregator approvals, lender accreditation, and the decision on how portal access is set up
Frequently asked questions
Can an offshore loan processing assistant submit the application to the lender?
Do I need to tell my aggregator before hiring an offshore loan processor?
Can my offshore assistant use my ApplyOnline or lender portal login?
What is the difference between a loan processor, a settlements coordinator and a broker support officer?
Do I have to tell clients their loan file is being processed overseas?
How long before an offshore loan processor is actually useful?
- National Consumer Credit Protection Act 2009 (Cth), s 8 (meaning of credit assistance), Ch 3 Pt 3-1 (responsible lending conduct for credit assistance providers), Pt 3-5A (best interests obligations) — The line between licensed credit assistance and administrative file processing
- ASIC Regulatory Guide 203: Do I need a credit licence? — Who must hold an Australian credit licence or act as an appointed credit representative
- ASIC Regulatory Guide 209: Credit licensing — responsible lending conduct — How the preliminary assessment and the not unsuitable test are expected to be approached
- ASIC Regulatory Guide 273: Mortgage brokers — best interests duty — That the best interests duty attaches to the broker and cannot be delegated to a support contractor
- Privacy Act 1988 (Cth), Australian Privacy Principles 1.4 and 5.2 (privacy policy and collection notice, including overseas recipients), APP 8 and s 16C (cross-border disclosure), Part IIIA (credit reporting) — Telling clients about overseas handling, and staying accountable for documents and credit information disclosed to an overseas recipient
- Office of the Australian Information Commissioner, Australian Privacy Principles guidelines, Chapter 8 (APP 8 — cross-border disclosure of personal information) — The distinction between using information inside your own systems and disclosing it overseas
- Your lender accreditation terms and your aggregator agreement (contractual, not statutory, and varying between them) — Separate named logins, no password sharing, and any approval needed before offshore support starts
Alfie is a natural facilitator with a passion for building meaningful relationships. A true people person, he thrives on creating genuine connections and bringing people and businesses together, and he excels at fostering collaboration and teamwork. At StaffingSolutions.io he is usually the first person you speak to: he maps the role, writes the brief the recruiters work from, and stays on the account long after the placement.
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