We've observed quite a few changes in ASIC's
approach to licence applications, especially over the past year or
two. This is the second and final blog in the series which
considers those changes, as well as the current trends in licence
applications and variations.
Competence of ACL responsible managers
If you applied for your ACL during or just after the transition
period, you may remember that ASIC's benchmark for competence
was "two years of relevant, problem-free experience" as
outlined in
RG 206. While the language in the guidance has not changed, we
have noticed significant differences in how ASIC is interpreting
the concept of "relevant experience".
During and just after the transition period, ASIC would accept
experience as relevant where someone had worked in a business
providing credit and had some experience in the provision of the
credit. It was unusual for an analyst to question the experience of
a potential responsible manager unless it was clear
