Draft ASIC RG104 (attached to Consultation Paper 110) will extend the compliance obligations of AFS licensees to credit licensees.
Even though credit licensees will not be obliged to report credit breaches as they occur they will still be obliged to make annual compliance reports:
“RG 104.31 Credit licensees are required to lodge with us a compliance certificate on an annual basis: s53, National Credit Act. In order to comply with this obligation, we expect that you will need to keep records of your monitoring and reporting, including records of reports on compliance and noncompliance.
Note: We will release an approved form in which credit licensees will be required to lodge their compliance certificates.”