How FinEase supports your hardship obligations

FinEase is designed around the frameworks Australian hardship teams work within. The platform supports your obligations with structured workflows, deadline visibility and consistent records — it does not provide legal advice or guarantee compliance.

Important

FinEase is an operations platform, not a compliance guarantee and not legal advice. Responsibility for meeting your obligations under the NCC, ASIC guidance, AFCA’s approach and the Privacy Act stays with your organisation. Templates and workflows are provided for your own legal and compliance team to review and adapt. We recommend consulting a qualified professional for specific questions.

NCC s72

Response deadline visibility

Deadlines are calculated from the date a hardship notice is logged, with dashboard alerts as they approach or pass. Your team decides how to act on them.

NCC s88

Default notice templates

Generate s88 default-notice templates that include the content lenders typically need — including hardship-rights and AFCA information — for your team to review before sending.

NCC s72(4)

Letter & document templates

Five templates generated as PDF: acknowledgement, approved arrangement, decline with reasons, default notice, and AFCA referral — configurable and reviewable by your team.

AFCA / NCC

AFCA escalation tracking

Track AFCA complaint references, escalation dates and outcomes. Configure decline letters to include AFCA contact details and external dispute resolution information.

ASIC RG 209

Structured hardship assessment

A structured assessment framework comparing declared income and expenses against bank statements and benchmarks, with decision support designed around ASIC RG 209.

ACCC/ASIC guidance

Vulnerability identification

Flag and track customer vulnerabilities (medical, family violence, disability, language, elder abuse) with handling protocols your team configures.

NCC record keeping

7-year record retention

Timestamped activity logs retained for 7 years. Every action is logged with user, timestamp and source, and can be exported to support audit preparation.

NCC / AFCA

Communication tracking

Log customer communications with dates, channels and content, building a communication history that supports AFCA matters and your own reviews.

Frameworks FinEase is designed around

These are the Australian frameworks the workflow is built to fit. They are provided as references for your own teams — not as an endorsement of FinEase by any regulator or scheme.

National Consumer Credit Protection Act 2009 (NCC)

s72Obligation to respond to hardship notices within 21 days
s72(4)Written reasons for declining a hardship variation
s88Default notice requirements including hardship rights
s94Enforcement action limitations during the hardship process

ASIC Regulatory Guide 209

RG 209.14Genuine assessment of repayment capacity
RG 209.20Reasonable inquiries into financial position
RG 209.30Use of benchmarks as a floor, not a ceiling

AFCA's approach

IDRInternal dispute resolution before external escalation
TimeframesComplaint acknowledgement and response timeframes
EDRExternal dispute resolution scheme details on decline communications

ACCC/ASIC debt collection guidance

HardshipConsider financial hardship before enforcement
VulnerabilitySpecial consideration for vulnerable consumers
CommunicationWritten communication expectations

See how FinEase supports your team

Book a demo to see the structured workflows, deadline visibility and records that support your own compliance and audit processes.

Book a demo