How to write a compliant NCCP file note (with checklist)

A file note is the broker's defence. If a complaint, audit, or AFCA dispute lands two years from now, the note you wrote after the call is the record that shows you did your job properly. A vague note that says "discussed options, client happy" tells a reviewer nothing. A defensible note shows the client's circumstances, what they wanted, what you assessed, and why the loan you recommended was not unsuitable for them.

This is a practical how-to for writing an NCCP-compliant file note, with a checklist you can use after every call. It covers the responsible lending obligations under the National Consumer Credit Protection Act, the s130 "not unsuitable" standard, and the parts brokers most often leave out. General guidance only, not legal advice. Check your licensee's own policy and your aggregator's requirements, because they often go further than the law.

What the law actually requires

As a credit assistance provider, you have responsible lending obligations under Chapter 3 of the NCCP Act. Before you suggest a particular credit product or assist a client to apply, you must do three things and keep a record of them.

1. Make reasonable inquiries about the client's requirements and objectives for the credit.
2. Make reasonable inquiries about the client's financial situation, and take reasonable steps to verify it.
3. Assess whether the credit contract is "not unsuitable" for the client based on those inquiries.

The verification step is the one people skip. "Reasonable inquiries" means you asked. "Reasonable steps to verify" means you checked - payslips, bank statements, a credit report, whatever fits the client. Your file note should show both the asking and the checking, or at least point to where the verification documents sit on file.

The seven things a defensible NCCP file note contains

Every broker file note should be able to answer these seven questions. If a reviewer can read your note and tick all seven, you have a defensible record.

1. Client circumstances and who was on the call

Date, time, channel (phone, video, in person), and who took part. If it is a joint application, note that both borrowers were present or how the absent party's instructions were obtained. Capture relevant personal context: dependants, employment type, whether someone is going on or off the loan, any change like a new baby or a planned move that affects the next few years.

2. Requirements and objectives

This is the heart of the note and the part most often too thin. Record what the client actually wants and why, in their words where you can. Not just "refinance" but "refinance to drop the rate and pull out $40k for a kitchen reno, wants to keep the offset, prefers a fixed portion because they are nervous about further rate rises". Loan purpose, loan amount, preferred features (offset, redraw, fixed vs variable, split), loan term, and any priorities they ranked - lower repayments now versus paying it off faster, certainty versus flexibility.

3. Financial situation (and how you verified it)

Income and its source, employment status and stability, existing debts and commitments, living expenses, assets, and any liabilities not on the application. Then the verification: what documents you sighted and when. "Verified income against two recent payslips dated X and Y and the June bank statement" is a real record. "Income confirmed" is not.

4. The "not unsuitable" assessment

State the product or products you assessed and your reasoning. Show that the loan meets their requirements and objectives and that the client can meet the repayments without substantial hardship. Reference the serviceability outcome. Then write the conclusion in the s130 language: based on the inquiries made and the information available, the recommended product is not unsuitable for the client.

5. Conflicts, alternatives considered, and why you chose this one

Note other options you looked at and why they were set aside. If you recommended a lender on your panel over a cheaper one for a genuine reason - serviceability policy, settlement speed, a feature the client needed - write that reason down. Disclose any conflict of interest or ownership relationship. This is also where commission and the best interests context belong if you are working under a licensee that requires it.

6. Fees, costs, and disclosures made

Record the fees disclosed and that the client received them: your credit guide, the Credit Quote and Credit Proposal where applicable, lender fees, LMI if relevant, break costs on any existing fixed loan, and any commission disclosure. Note that the client understood and agreed.

7. Decisions, instructions, and next steps

What was decided, what the client instructed you to do, and the agreed actions with owners and rough timing. "Client instructed me to proceed with Lender X variable, I am ordering a valuation today and will send the application for signing by Friday." If the client went against your recommendation, record that clearly along with the fact that you set out the risks.

A copy-and-keep checklist

Run through this after every client call. If you can tick all of it, the note will stand up.

• Date, time, channel, and everyone present recorded
• Requirements and objectives captured specifically, in the client's words where possible
• Financial situation recorded - income, expenses, debts, assets
• Verification documents listed (what you sighted, when)
• Products assessed and the reasoning written out
• Conclusion stated as "not unsuitable" under s130, not "suitable" or "best"
• Alternatives considered and conflicts disclosed
• Fees and required disclosures made and acknowledged by the client
• Client instructions and next steps with owners and timing
• Note dated, attributed to you, and locked so it cannot be quietly edited later

How long this takes, and where the time goes

Done properly by hand, a file note like this takes a good ten to fifteen minutes per call. The information is all in the conversation you just had - you are just transcribing your memory into a structured record while juggling the next client. That is why notes get thin by Friday afternoon, and thin notes are exactly the ones that fail under scrutiny.

The fix is not to write less. It is to start from the transcript of the call instead of a blank page. If you have the words that were actually said, the requirements, the figures, the instructions are already there - you review and confirm rather than recall and retype.

How CallNote drafts an NCCP note from the transcript

CallNote does not record or transcribe your calls. It receives the transcript your phone or meeting system already made - you paste it, forward it by email, upload a voice memo, or connect a phone system like Dialpad - and generates a structured file note from it in about two minutes.

The relevant part here is the NCCP loan suitability template. It is built around the seven elements above: client circumstances, requirements and objectives, financial situation, the "not unsuitable" assessment in the correct s130 wording, conflicts, fees disclosed, and next steps. It pulls what the transcript actually contains into each section, and flags where something is missing so you can fill the gap before you lodge. A broker declaration is included and sealed into the note.

You stay in control of the wording. CallNote uses your own house style and prompt, not a fixed form you have to bend your practice around. The flow is simple: Generate from the transcript, Review and correct on screen, then Lodge and Lock. Once locked, the note is timestamped, SHA-256 sealed, and append-only, so any later amendment is added as a dated entry rather than a silent rewrite. That is the contemporaneous, tamper-evident record a reviewer wants to see.

It is all hosted in Australia (AWS Sydney), encrypted, and your data is never used to train AI models. For the broader picture of which tools handle this well, see our roundup of file note software for mortgage brokers. And before you record any call to get a transcript in the first place, read the rules on recording phone calls in Australia - consent rules differ by state.

Common questions