ASIC Report 840 · October 2026

Protect or ExposeASIC Report 840 guides for mortgage brokers

ASIC has made the bar clear. The question is no longer “Is there a note on the file?” It’s “Can you prove the decision was sound?” Get the 9 checks every file should pass, plus an interactive scorecard to test your own files before a reviewer does.

Choose your guideSee what’s inside

By Stephen Soo, CPA · 17 years in audit and risk management · 2026 Silver Stevie, Mentor of the Year

Covers of the two Protect or Expose guides to ASIC Report 840, by Stephen Soo, CPA

Why this matters now

ASIC checked 1,600 loan files. Now every licensee will look harder.

ASIC reviewed how 8 large aggregator groups oversee their brokers. If you write home loans, these findings land on your files.

80%+of home loans now go through mortgage brokers
1,600loan recommendations reviewed by ASIC
7 of 8groups had brokers who didn’t recommend the lowest cost loan in more than 20% of cases
44%of files had missing, generic or poor reasons once the extra cost passed $20,000

Source: ASIC Report 840, Mortgage brokers: Review of best interests duty and complaints handling practices (13 October 2026).

Choose your guide

Two editions. Pick the one that matches your licence.

Cover of Protect or Expose: Report 840 for Brokers Under an Aggregator
Under an aggregator

Non ACL brokers

You write loans as a credit representative under your aggregator’s credit licence.

AUD$27

  • The 9 checks every file should pass
  • The cost gap explained, with a worked example
  • Weak note vs strong note, side by side
  • Red-flag phrases to rewrite
  • Score yourself out of 9
  • Interactive scorecard: score 5 files and work out your cost gap

13-page PDF · Interactive scorecard · Free bonus checklist

Buy now – AUD $27
Cover of Protect or Expose: Report 840 for ACL Holders
Own licence

ACL holders

You hold your own Australian credit licence. You’re the broker and the checker, and no compliance team sits above you.

AUD$39

  • The 9 checks every file and licence should pass
  • Checks for your file review program and complaints register
  • What else ASIC expects of your licence, in one table
  • The cost gap, weak vs strong note and red-flag phrases
  • Score your licence out of 9
  • Interactive scorecard: score 5 files and work out your cost gap

14-page PDF · Interactive scorecard · Free bonus checklist

Buy now – AUD $39

Free bonus with every guide: the Best Interests File Note Check, a one-page desk checklist to run before you submit. I’ll email it to you as soon as it’s ready.

Not sure which one? If you work under your aggregator’s licence as a credit representative, choose Non ACL brokers. If your business holds its own ACL number, choose ACL holders.

What’s inside

4 parts. 9 checks. One hour with 5 of your own files.

ASIC’s findings come down to 4 parts and 9 checks. A file that passes all 9 protects you. A file that can’t, exposes you.

Part 1Make a sound decision

  1. 1The full picture
  2. 2The right fit
  3. 3The real numbers
  4. 4The trade-off

Part 2Write down why

  1. 5The paper trail
  2. 6The timestamp
  3. 7The stranger test

Part 3Pass the check

  1. 8The second look

Part 4Pass on every complaint

  1. 9The open door

The ACL edition adds checks for your file review program, your complaints register and your licence.

1

Pull 5 recent files: 3 settled, 1 declined or withdrawn, and 1 where you didn’t recommend the lowest cost loan.

2

Run each file through the 9 checks. The cost gap, example notes and red-flag phrases show you what good looks like.

3

Score yourself out of 9 in the interactive scorecard. Close the gaps before a reviewer finds them.

A taste of what’s inside

Would your note survive a reviewer?

WEAK NOTE

Client is self-employed. Lender B suits client’s needs. Client happy to proceed.

This note could sit on any file, so it proves nothing. The guide shows you the strong version: one paragraph that covers 6 of the 9 checks.

Do your notes lean on phrases like these?

“Client preference”“Suits client’s needs”“Best rate”“Fast turnaround”“Client wants to stay with their bank”

The guide shows why each one gets flagged, and what to write instead.

Choose your guide
Stephen Soo, CPA, business coach for mortgage brokers

Why this guide reads Report 840 differently

If it’s not on file, it didn’t happen.

Most summaries of Report 840 list what ASIC found. This one sorts it the way an auditor checks a file.

I spent 17 years in audit and risk management, starting at a Big 4 audit firm, then GE Capital, ANZ and NAB. I’m a CPA. Audit teaches you one rule early, and it’s the rule your reviewer will use on your files.

Silver Stevie Winner 2026 International Business AwardsStephen Soo, CPAInternational Multi-Award-Winning Business Coach · 2026 Silver Stevie, Mentor of the Year

FAQ

Frequently asked questions

ASIC Report 840, Mortgage brokers: Review of best interests duty and complaints handling practices, came out on 13 October 2026. ASIC reviewed how 8 large aggregator groups oversee their brokers’ best interests duty and complaints handling, and found room for improvement.

If you write loans as a credit representative under your aggregator’s credit licence, choose Non ACL brokers (AUD $27). If your business holds its own Australian credit licence, choose ACL holders (AUD $39).

Pay at checkout and your download link appears straight away. It’s also emailed to you, with the link and password for your interactive scorecard. The guide is a PDF you can read on any device or print.

An online tool that works on your phone or computer. Name your 5 files, tick each one that passes each check, and it gives you your score out of 9. It also works out your cost gap and shows what your note needs. Your answers stay in your browser and are never sent to anyone.

The Best Interests File Note Check, a one-page desk checklist to run before you submit a file. It’s free with every guide, and I’ll email it to you as soon as it’s ready.

No. The guides are general information only. They summarise ASIC Report 840 and my views on good practice. They are not legal, compliance, financial, tax or credit advice, and they are not endorsed by ASIC. Always check your licensee’s policies and ASIC’s guides, including RG 273 and RG 271.

Each guide is licensed for the buyer’s own use. If you want copies for your team or everyone under your licence, book a meeting and I’ll set it up.

All sales are final. Because the guide is an instant digital download, I don’t give refunds if you simply change your mind. This doesn’t affect your rights under the Australian Consumer Law. If your file is faulty or doesn’t match what this page describes, email admin@stephensoocoaching.com and I’ll fix it.

You may be able to claim it as a business expense. Check with your accountant or visit the ATO website for confirmation.

Your files will be checked. Check them first.

Pick your edition, set aside an hour and run 5 of your files through the 9 checks.

Non ACL brokers – AUD $27ACL holders – AUD $39

Scored under 9? Book a meeting and I’ll help you build the fix into your week.

General information only. These guides were prepared by Stephen Soo Coaching (ABN 99 422 705 854). They are not legal, compliance, financial, tax or credit advice and do not take into account your circumstances or your licensee’s policies. They summarise ASIC Report 840 (October 2026) and the author’s views on good practice. The 9 checks, scoring, cost gap bands and example notes are the author’s views, not ASIC requirements. Not endorsed by or affiliated with ASIC. Each guide is licensed for the buyer’s own use.