If you have an Australian Financial Services Licence (AFSL), your work in complying with your Australian Credit Licence (ACL) should be easier. That’s because the obligations under an AFSL and ACL are very similar – almost word for word – although of course they deal with different products and services.

The conflicts of interest obligation is different. Under your ACL, you must have adequate arrangements to ensure that customers are not disadvantaged by conflicts of interest. Under your AFSL, your obligation is to have adequate arrangements to manage conflicts of interest.

There are other obligations under the Corporations Act for AFSLs and the National Consumer Credit Protection Act for ACLs which are different.

In its regulatory guide RG204: Applying for and varying a credit licence, ASIC says it expects that if you are granted an ACL, you will comply with your obligations by maintaining the same types of arrangements in relation to your credit activities as you use for compliance with your AFSL.