How this works

The obligation. Since 1 January 2021 an Australian mortgage broker must act in the best interests of the consumer when providing credit assistance — Pt 3-5A of the National Consumer Credit Protection Act 2009, s 158LA and s 158LE — and must prioritise the consumer's interests where there is a conflict, s 158LB and s 158LF. ASIC's guidance is Regulatory Guide 273. The sentence that decides what this product is:

We expect that evidence of compliance with the best interests obligations will come predominantly from the broker’s records.

RG 273.21, Regulatory Guide 273 Mortgage brokers: Best interests duty

The obligation is discharged in a document. So the document is what this makes.

The arithmetic.

We generally expect the cost of a credit product—such as interest rate, fees and charges and the size of repayments—to be a factor that mortgage brokers should prioritise.

RG 273.51, Regulatory Guide 273 Mortgage brokers: Best interests duty

Cost is not the interest rate. It is the rate over a stated window, plus the fees, less the quantifiable promotions, with an offset modelled against a real balance and a fixed period that reverts — and it is computed month by month rather than with a formula, because everything that makes one product cheaper than another is a discontinuity a formula would smooth away. Every total on this surface opens onto the steps that made it, and every option opens onto a schedule with a row for each month.

The refusing. RG 273 names a small number of places where a broker should record a reason, and a file here will not seal without them. That is not this software deciding anything. It is this software declining to produce a document with a hole in exactly the place the regulator has announced it is looking.

The situation	What ASIC says
Only one option presented RG 273.89	As a matter of good practice, you should present a consumer with more than one option, unless there is a good reason not to.
Every option from the same credit provider RG 273.95	If all the options presented to a consumer are for products from the same credit provider, you should explain this and provide reasons for this to the consumer.
A product is not available to this consumer RG 273.61	In these situations, you should: (a) explain why the products are not available and the limitations involved with the available option(s).
A higher cost loan is recommended RG 273.54	Any situation where a higher cost loan is recommended will need to be supported by evidence demonstrating why that recommendation is in the consumer’s best interests.

What this software does not say.

• Whether the obligations in Pt 3-5A of the National Credit Act were discharged. That is a conclusion about the broker’s own conduct; it belongs to the broker, their licensee, and ultimately to ASIC or a court.
• Which product is right for this consumer. The options were selected by the broker and the recommendation is the broker’s, recorded here in their name.
• Any ranking of credit providers on service, turnaround, policy or relationship. Those were not measured, and RG 273.77 expects claims of that kind to be evidence-based.

Creditcrest Technologies is not a credit provider, is not a credit assistance provider, and does not hold an Australian credit licence. Its software produces evidence; the licensee makes the decision.

It will not write the reasons. ASIC's Commissioner has said that reasons which are "boilerplate factors that could apply to anyone" will be hard to demonstrate. A generated paragraph is therefore not a shortcut to a good file: it is the specific defect, reproduced identically across every file written with the same tool. So the narrative fields on this surface are empty until a person types in them, and nothing here offers a draft.

It will not pre-select an option. Which product is in this consumer's best interests is the broker's judgement. A surface that proposed the cheapest and invited a signature would be making the recommendation and recording somebody else's name against it.

In the address bar, and nowhere else. A file here is its own link and nothing is stored, so the file is exactly as long as the address bar allows. 2,000 characters is the length that opens anywhere — it is Internet Explorer’s maximum of 2,083, which is the floor no other client went below. Past about 8,000 this server itself will refuse the request, because Node’s HTTP parser caps the whole header block at 16 KiB and the address is part of it.

A file that has outgrown a link is a real file, not a mistake. Shorten it by keeping the narrative where the licensee already keeps it and carrying the costing here, or seal it and keep the sealed artefact — the page at /broker/file.html is one self-contained HTML file that can be saved and filed. What this software will not do is quietly start a database and stop telling you where your consumer’s circumstances are held.

Sealing computes a SHA-256 over a canonical serialisation of the file with the seal date on it. The date is in the link for that reason: the hash is recomputed from the link every time the page is opened, so whoever receives it can check the seal themselves instead of trusting a badge this page drew.

ASIC prescribes no comparison period. Regulatory Guide 273 sets no term, no amount and no horizon over which the cost of credit is to be compared, and the paragraph that comes closest — RG 273.58, on refinancing — names no period either.

The only comparison basis Australian law prescribes is regulation 97 of the National Consumer Credit Protection Regulations 2010, made for s 161(2) of the National Credit Code:

For subsection 161(2) of the Code, the designated amounts and terms for which a comparison rate is to be calculated are: (a) $250 for a term of 2 weeks; and (b) $1,000 for a term of 6 months; and (c) $2,500 for a term of 2 years; and (d) $10,000 for a term of 3 years; and (e) $30,000 for a term of 5 years; and (f) $150,000 for a term of 25 years.

National Consumer Credit Protection Regulations 2010 (Cth), reg 97

Section 161 is in the comparison-rate provisions of the Code, which govern what a credit advertisement must show. Regulation 97 is therefore not a standard for a best interests cost comparison and is not used as one here. It is cited because it is the only comparison basis Australian law prescribes at all, and because it settles what the window is not: the figure in the regulations is $150,000 over 25 years, and five years is the pair prescribed for $30,000.

Regulation 97 writes its amounts with a non-breaking space as the thousands separator — "$150 000". The quotation above uses the comma an Australian reader expects; no other character has been changed. National Consumer Credit Protection Regulations 2010 (Cth), compilation No. 57, compilation date 5 September 2026; National Credit Code (Schedule 1 to the National Consumer Credit Protection Act 2009), compilation No. 52, compilation date 1 July 2026.