An effective ACL compliance framework shows how you identify obligations, allocate responsibility, monitor compliance, escalate issues and report to management or the board.
For credit licensees, that framework should reflect the obligations that apply to your credit activities, representatives, disclosures, complaint handling, reportable situations, breach reporting, and, where relevant, responsible lending and consumer protection requirements. ASIC expects more than static policies. You need systems and processes that support lawful and competent day-to-day operations.
In practical terms, that usually includes an obligations register, clearly defined roles, training and supervision settings for credit representatives, monitoring and review programs, breach and incident processes, governance reporting, complaints handling, and regular testing to ensure controls are working.