First home buyer file notes: what a broker must document

Why first home buyer files need more

The best interests duty in s 158LA applies to every consumer you help, but ASIC's guidance in RG 273 ties the steps you take to the client's circumstances. A first home buyer usually has a small deposit, little experience with credit, and several ways to buy the same property that carry very different costs and risks. That widens the set of options a reasonable broker should consider, and widens what your file needs to show you considered.

It also raises the conflict risk. A higher LVR means a bigger loan, and schemes limit you to participating lenders. Under s 158LB you must prioritise the client's interests where there is a conflict. A clear note of why a particular lender and structure was chosen is the evidence that you did. For the fundamentals of the duty see our guide to best interests duty file notes for brokers, and for the responsible lending side see how to write a compliant NCCP file note.

Requirements and objectives: go past 'buy first home'

Section 117 requires reasonable inquiries about the client's requirements and objectives, and s 118 treats a contract as unsuitable if it will not meet them. 'FHB wants to buy first home' records nothing. Useful FHB objectives are specific:

• Purchase price range, location and property type, and whether it is established, new, off the plan or a build.
• Timeframe, and whether they are pre-approval shopping or have a contract.
• How long they plan to stay, and whether they might rent it out later (this matters for scheme eligibility).
• Repayment preference: P&I or IO, fixed, variable or split, and why.
• Features they asked for: offset, redraw, extra repayments, a package.
• Priorities if they conflict, for example lowest upfront cost versus lowest total cost.
• Known future changes: a planned career break, a baby, a partner returning to study.

Write down the client's stated reason as well as the requirement. 'Wants offset - expects bonus + wants flexibility before kids' shows a real inquiry. It also shows why you recommended a product with a slightly higher rate.

Deposit, LVR and LMI: record the options you compared

Most FHBs are choosing between waiting to save more, paying LMI, or using a scheme or guarantor to avoid it. Each route has a real cost, and the right answer depends on the client. The file should show the dollar cost of each route and the reason you chose the one you did.

Government schemes: what the rules are in 2026

The Australian Government 5% Deposit Scheme

The Home Guarantee Scheme is now called the Australian Government 5% Deposit Scheme and is administered by Housing Australia. From 1 October 2025 the Scheme was expanded: there are no income caps, no limit on places and no waiting list, and eligible buyers do not pay LMI because the Government guarantees part of the loan to the lender. According to the official first home buyers site, the main criteria for the first home buyer stream are:

• Australian citizen or permanent resident, at least 18 years old.
• A minimum 5% deposit (2% for eligible single parents or legal guardians).
• A first home buyer, or has not owned property or land in Australia in the last 10 years.
• Buying a home at or below the price cap for its location.
• Will live in it as an owner-occupier; investment properties are not eligible.
• An OO P&I loan from a participating lender, up to 30 years (plus up to three years to build).
• Applying alone or jointly with one other person (a partner, friend or family member).
• Meets the participating lender's own credit policy.

Price caps vary by location and changed with the October 2025 expansion. Use Housing Australia's price cap tool for the actual suburb and write the cap and the date you checked it in your note. Also record that you explained the ongoing obligations: the client must keep living in the property, and if they stop meeting the conditions the guarantee may fall away and the lender may require LMI or other costs.

Help to Buy

Help to Buy is a shared equity scheme. The client needs a minimum 2% deposit and the Government contributes up to 30% of the price for an existing home or up to 40% for a new one, taking a matching equity share. It has income limits (wage indexed annually), requires Australian citizenship, and has a set number of places each year. Clients cannot combine it with state or territory shared equity schemes, loans or guarantees, though state stamp duty concessions and grants can still apply. Because the Government shares in gains and losses when the client sells or buys back its share, your note should show you explained that trade-off, and why it did or did not suit this client over the 5% Deposit Scheme.

FHSS, state grants and stamp duty

Under the First Home Super Saver Scheme a client can release voluntary super contributions (up to $15,000 a year and $50,000 in total) toward a deposit, but they must request an FHSS determination from the ATO before the property transfers to them. If a client plans to use it, note the timing. First home owner grants and stamp duty concessions are set by each state and territory, change often, and usually depend on price thresholds and whether the home is new. Rather than quoting figures from memory, note which state scheme you checked, the source (the state revenue office) and the date.

Genuine savings, gifted deposits and guarantors

Where the deposit comes from is a verification issue under s 117 and a lender policy issue. Record the source of every part of it:

• Genuine savings. Many lenders want evidence of savings held or built up over a period, especially at higher LVRs. The rules are lender policy and vary, so record which lender's policy you checked and whether the client meets it.
• Gifted funds. Record who is giving the money, the amount, and whether it is a true gift. Most lenders ask for a gift letter or statutory declaration. If the money is really a loan from family, that repayment is a liability that affects servicing, and the note should say you asked.
• Guarantors. A family guarantee can avoid LMI, but the guarantor puts their own property at risk. The guarantor is not your client, and most lenders require them to get independent legal advice. Your note should record what you explained to the borrower about the guarantor's exposure, the amount of the guarantee, and how and when it can be released.
• FHSS and other sources. Note the amount and timing of any FHSS release, sale of assets or bonus, and whether the funds are verified or expected.

Servicing and verification

First home buyers are often stretching. Record the income you verified and how (payslips, PAYG summary, employer letter), living expenses and how you tested them against the lender's benchmark, existing debts including BNPL and HECS-HELP, and the buffer you and the lender applied. If the client's plans include a drop in income, such as parental leave, record that you asked and how it was treated. Under s 118 a contract is unsuitable if the client could only meet repayments with substantial hardship, and the note is where you show why that is not likely.

Checklist: first home buyer file note

1. Date, attendees, mode of meeting, and credit guide provided.
2. Requirements and objectives, with the client's reasons in their words.
3. Purchase details: price range, location, property type, timeframe.
4. Deposit amount and source, verified or pending, including gifts and FHSS.
5. Options compared: 20% deposit, LMI, 5% Deposit Scheme, Help to Buy, guarantor, with costs.
6. Scheme eligibility checked criterion by criterion, price cap and date checked.
7. Income, expenses and liabilities verified, and the buffer applied.
8. Lenders and products considered, and why each was or was not chosen.
9. Recommendation and why it is in the client's best interests (s 158LA).
10. Any conflict (commission, lender panel limits) and how you prioritised the client (s 158LB).
11. Risks explained: ongoing scheme obligations, rate rises, guarantor exposure.
12. Client's decision and next steps.

You can test a draft against the NCCP file note compliance checklist, or start from our mortgage broker file note template.

Worked example: a first home buyer file note

Fictional clients, and the note a broker would make from the meeting.

The note shows every option on the table and why three were set aside. It shows the scheme criteria were checked, including the price cap with a date. It links the recommendation back to the clients' own priorities, including a future income drop, and records that the lower-rate lender was rejected for a reason the clients would care about.

Getting the note written

The hardest part of an FHB file is that first meeting, which often runs long and covers all of the above. If you meet on Teams or Zoom, or take calls through Dialpad or Aircall, the transcript already holds most of the detail. CallNote takes that transcript and produces a structured note in your own format in about two minutes. It never records the call or joins as a bot. It has an NCCP template, or you can paste one of your own past notes and it builds a template around your headings and shorthand. You review the draft, then publish it seals it so later changes are added as amendments. There is no direct link into Mercury or Salestrekker, so the note goes onto the deal by copy and paste or PDF. See CallNote for mortgage brokers for how teams set it up.

Scheme details in this article are drawn from the official first home buyers site run by Housing Australia as at September 2026. Criteria and price caps change, so check the current rules for each client. This is general information, not legal or financial advice.

Common questions