Good Money

Regulatory Compliance Register
Prepared: March 2026 | Version 1.0
Good Money Pty Ltd | ABN: Pending
CONFIDENTIAL

Contents

  1. Licensing Requirements
  2. Corporations Act 2001 — Financial Services
  3. National Consumer Credit Protection Act 2009
  4. Design and Distribution Obligations (DDO)
  5. Privacy Act 1988 — Australian Privacy Principles
  6. AML/CTF Act 2006 — AUSTRAC
  7. ASIC RG 221 — Digital Disclosures
  8. ASIC RG 271 — Internal Dispute Resolution
  9. Insurance-Specific Regulations
  10. Superannuation-Specific Regulations
  11. Electronic Transactions Act 1999
  12. Consumer Data Right (CDR) / Open Banking
  13. Anti-Hawking Provisions
  14. Best Interest Duty — Financial Advice
  15. Dual-Currency (Happy Cash / Good Cash) Compliance
  16. App Feature Compliance Matrix
  17. Pre-Launch Regulatory Checklist

1. Licensing Requirements

Good Money requires multiple concurrent licences to operate as a product manufacturer and distributor across all financial categories.

LicenceRegulatorLegislationProducts CoveredStatus
AFSL (Australian Financial Services Licence)ASICCorporations Act 2001, s912AInsurance, superannuation, managed investments, financial advicePending
ACL (Australian Credit Licence)ASICNCCP Act 2009, s35Mortgage lending, credit provisionPending
AUSTRAC RegistrationAUSTRACAML/CTF Act 2006All designated servicesPending
RSE LicenceAPRASIS Act 1993Superannuation fund operationPending
MGA AgreementUnderwriterInsurance Contracts Act 1984Insurance underwriting authorityPending
CDR AccreditationACCCCompetition and Consumer Act 2010, Part IVDOpen Banking data accessPending
Interim Strategy: Operate as Corporate Authorised Representative (CAR) of a licenced entity while AFSL/ACL applications are processed (est. 4–12 months). Broker-first hybrid model generates revenue during licensing period.

Responsible Manager Requirements

ASIC requires at least one Responsible Manager (RM) per AFSL with:

Capital / Financial Resource Requirements

Licence TypeNet Tangible Assets (NTA)Additional Requirements
AFSL — General Advice$50,000Adequate cash resources
AFSL — Personal Advice$150,000Professional Indemnity insurance
AFSL — Custodial$10,000,000 or 10% of AUMAudited financial statements
ACL — Credit Provider$2,000,000+Based on credit volume
RSE Licence$5,000,000APRA operational risk capital

2. Corporations Act 2001 — Financial Services

Part 7.7 — Financial Services Guide (FSG)

An FSG must be provided to retail clients before or when a financial service is provided (s941A–942C). Under the Delivering Better Financial Outcomes (DBFO) Act 2024 amendments (effective Jan 2025), AFS licensees can satisfy FSG obligations by publishing on their website.

FSG Must IncludeApp ImplementationStatus
Licensee name, contact details, ABN, AFSL numberLicenceDisclosure component + Settings LEGAL sectionPlaceholder — awaiting AFSL
Services and products offeredProduct catalog in ProductContextImplemented
How the licensee is paid (remuneration)Not yet implementedPending
Associations or relationships that may influence adviceNot yet implementedPending
Complaints handling procedureDisputeResolutionNotice componentImplemented
Compensation arrangementsNot yet implementedPending

Part 7.9 — Product Disclosure Statement (PDS)

A PDS must be given to a retail client before the product is issued or sold (s1012A–1012C). The PDS must be up-to-date and can be provided electronically under ASIC Instrument 2025/447.

PDS RequirementApp ImplementationStatus
PDS must be provided before acquisitionProductDisclosureNotice on marketplace cards + application flowImplemented
PDS links accessible on product pages"View PDS" links on every product cardImplemented
Supplementary PDS for material changesURL-based — updatable without app releaseArchitecture Ready
Short-form PDS optionNot yet implementedPending

Section 949A — General Advice Warning

When providing general advice to a retail client, the provider must warn that the advice does not consider the client's personal objectives, financial situation or needs.

RequirementApp ImplementationStatus
General advice warning on all recommendation screensGeneralAdviceWarning component — amber-styled box on marketplace cards, application form, product tabsImplemented
Warning must be prominent and not hiddenDisplayed at top of application flow, bottom of marketplace sectionsImplemented

Section 992A — Anti-Hawking

Unsolicited offers of financial products to retail clients are prohibited. Products must only be offered in response to a request by the client.

RequirementApp ImplementationStatus
Products shown at user's request (not pushed)Anti-hawking text: "You have chosen to view these products. This information is provided at your request."Implemented
No unsolicited push notifications for product offersProduct notifications not implementedCompliant (no push marketing)

3. National Consumer Credit Protection Act 2009 (NCCP)

Credit Guide (s126–128)

A Credit Guide must be provided as soon as practicable when it becomes apparent a credit contract may be entered. For digital applications, this must be accessible before the application begins.

RequirementApp ImplementationStatus
Credit Guide provided before credit assistanceCreditGuideNotice component shown at step 0 of mortgage applicationsImplemented
Credit Guide link accessible"View Credit Guide" link on mortgage product cardsImplemented
Credit Guide content (services, fees, complaints, associations)Document URL points to goodmoney.com.au — content pendingPlaceholder URL

Key Facts Sheet (Schedule 5, NCCP Regulations)

Lenders with websites must enable consumers to generate a personalised Key Facts Sheet for standard home loans. Failure to provide is a criminal offence + civil penalty (up to $220,000/breach).

RequirementApp ImplementationStatus
KFS available on website / in-appKeyFactsSheetNotice component with "View Key Facts Sheet" linkImplemented
Personalised comparison rate based on consumer's loan amountNot yet implemented — requires dynamic KFS generationPending
KFS must include: interest rate, comparison rate, monthly repayments, total cost, feesMortgage tab shows rate and repayment calculations; formal KFS document pendingPartial

Responsible Lending Obligations (s128–133)

ObligationApp ImplementationStatus
Make reasonable inquiries about financial situationFinancial Fact Find collects income, expenses, assets, liabilitiesImplemented
Make reasonable inquiries about requirements and objectivesApplication form collects loan purpose, term, LVR preferencesImplemented
Take reasonable steps to verify financial situationBasiq Open Banking integration provides verified transaction/balance dataImplemented
Assess that credit is "not unsuitable"Best Interest recommendation engine checks suitabilityPartial — needs formal unsuitability assessment
Provide written assessment on requestAudit trail in ProductContext generates assessment reasoningPartial — needs formal document generation

Cooling-Off Period — Credit Contracts

Important: Cooling-off rights do NOT apply to credit contracts (home loans) under the National Credit Code. The app correctly distinguishes this — mortgage applications show "No Cooling-Off Period — Credit Contract" while insurance/super show 14-day notices.

Comparison Rate Schedule (Schedule 2, NCCP Act)

Any advertisement or disclosure of a credit interest rate must include a comparison rate calculated in accordance with Schedule 2. The comparison rate is based on a secured loan of $150,000 over 25 years.

RequirementApp ImplementationStatus
Comparison rate displayed alongside interest rateDisclaimer on mortgage tab references comparison rate basisPartial — needs calculated comparison rate per product
Warning about comparison rate limitations"WARNING: This comparison rate is true only for the examples given..." text on mortgage tabImplemented

4. Design and Distribution Obligations (DDO)

Part 7.8A of the Corporations Act 2001 (commenced 5 October 2021). Applies to all financial products offered to retail consumers. Governed by ASIC Regulatory Guide 274 (RG 274).

Target Market Determination (TMD)

ObligationApp ImplementationStatus
TMD must be prepared before product is first offeredTMD URLs defined in compliance.ts for each product categoryPlaceholder — TMD documents pending
"View TMD" link accessible to consumers"View TMD" links on all product cards and in application flowImplemented
Consumer must acknowledge TMD before acquisitionTargetMarketNotice component + mandatory TMD checkbox in application formImplemented
Review triggers defined in TMDNot yet implemented — requires TMD document contentPending
Distribution conditions and restrictionsBest Interest recommendation engine restricts unsuitable recommendationsImplemented
Distributor reporting obligations to issuerProductContext tracking logs comparisons and applicationsPartial — needs formal reporting

Issuer vs Distributor Obligations

Where Good Money manufactures its own products, it is both issuer AND distributor. Both sets of obligations apply. Where distributing third-party products, Good Money is a distributor only and must comply with the issuer's distribution conditions.

5. Privacy Act 1988 — Australian Privacy Principles

APPObligationApp ImplementationStatus
APP 1Open and transparent management of personal infoPrivacy Policy URL; PrivacyCollectionNotice componentImplemented
APP 3Collection of solicited personal info — only what's necessaryFact Find collects financial data for stated purposesImplemented
APP 5Notification of collectionPrivacyCollectionNotice shown before data collection in application formsImplemented
APP 6Use or disclosure limited to purpose of collectionData used for product recommendations and applicationsImplemented
APP 8Cross-border disclosure of personal infoNo cross-border data transfers currentlyCompliant
APP 11Security of personal informationAsyncStorage (device-local); Basiq uses encrypted CDR pipelinePartial — needs server-side encryption policy
APP 12Access to personal information"Your data stays on your device" notice; data export not yet availablePartial
APP 13Correction of personal informationUsers can edit all data via Fact Find and setup screensImplemented

Health Data — Special Considerations

Health data from wearables (Apple Health, Oura, Whoop, Fitbit, Garmin) is "sensitive information" under the Privacy Act. Collection requires explicit consent and can only be used for the stated purpose (insurance premium assessment).

RequirementApp ImplementationStatus
Explicit consent for health data collectionConnect/disconnect buttons per platform; user-initiated onlyImplemented
Purpose limitation (insurance pricing only)Health data used for Health Score and insurance premium estimatesImplemented
Right to disconnect/delete health datadisconnectHealth() function per platformImplemented

6. AML/CTF Act 2006 — AUSTRAC

As a provider of designated services (financial products, credit), Good Money must register with AUSTRAC and implement an AML/CTF program.

ObligationDescriptionStatus
Customer Identification (KYC)Verify customer identity before providing designated servicesPending — requires ID verification integration
Transaction MonitoringMonitor for suspicious transactions and report to AUSTRACPending
Suspicious Matter Reports (SMRs)Report suspicious matters within 24 hours (terrorism) or 3 daysPending
Threshold Transaction Reports (TTRs)Report cash transactions of $10,000+Pending
AML/CTF ProgramWritten program covering Parts A (governance) and B (KYC)Pending
Record KeepingRetain records for 7 yearsPending

7. ASIC RG 221 — Facilitating Digital Financial Services Disclosures

Updated December 2025. Permits "publish and notify" method for electronic disclosures. No longer requires explicit client consent for digital delivery.

Key Requirements for Digital Delivery

RequirementApp ImplementationStatus
Stable URLs for disclosure documentsDocument URLs defined in compliance.ts (goodmoney.com.au/documents/)Placeholder URLs
Documents accessible without login for initial accessArchitecture supports public URLsPending — documents not yet hosted
Mobile-friendly formatApp is mobile-first; all compliance text renders responsivelyImplemented
Notification of document availabilityIn-app display of document links at point of needImplemented
Record-keeping of notificationsProductContext tracks when users view comparisons/applicationsPartial
Paper copy available on requestNot yet implementedPending
WCAG 2.1 accessibilityAccessibilityContext provides font scaling; VoiceOver labels on key elementsPartial

ASIC Corporations (Electronic Disclosure) Instrument 2025/447

Consolidates prior instruments (2015/647 and 2015/649). Allows publish-and-notify for PDS, FSG, SoA, periodic statements, and annual reports for managed schemes. Relaxes format requirements — no need to be "paper-like".

8. ASIC RG 271 — Internal Dispute Resolution

RequirementTimelineApp ImplementationStatus
Acknowledge complaint1 business day (standard); 5 business days (certain complaints)DisputeResolutionNotice references RG 271 timeframesImplemented
Resolve complaint — standard30 calendar daysDisclosed in dispute resolution textImplemented
Resolve complaint — hardship/default21 calendar daysDisclosed in dispute resolution textImplemented
Resolve complaint — superannuation45 calendar days (90 for death benefits)Not separately specifiedPartial
AFCA referral informationIf not resolved to satisfactionAFCA phone (1800 931 678), website, email providedImplemented
AFCA membership numberRequiredPlaceholder — pending membershipPlaceholder

9. Insurance-Specific Regulations

Insurance Contracts Act 1984

ObligationDescriptionApp ImplementationStatus
Duty of Disclosure (s21)Insurer must inform consumer of duty to disclose material factsNot yet in application flowPending
Duty of Utmost Good Faith (s13)Both parties must act with utmost good faithBest Interest recommendation enginePartial
Cooling-off (s59A)14 days from receipt of policy documents for general insuranceCoolingOffNotice (insurance variant) — 14-day noticeImplemented
Unfair Contract TermsStandard cover provisions; unfair terms are voidPDS reference directs to full termsImplemented

General Insurance Code of Practice 2020

Industry self-regulation code administered by the Insurance Council of Australia. Key provisions include plain language requirements, claims handling timeframes, and vulnerability support.

Health Data for Insurance Pricing

Regulatory Risk: Using wearable health data for insurance pricing is novel in Australia. While life insurance uses health questionnaires, real-time wearable data for home/contents/motor insurance pricing has limited actuarial basis. Start as MGA on established insurer's paper (SWOT T8 mitigation). ASIC may require additional disclosure about how health data affects pricing.

10. Superannuation-Specific Regulations

Superannuation Industry (Supervision) Act 1993 (SIS Act)

ObligationDescriptionApp ImplementationStatus
RSE LicenceRequired to operate a superannuation fundNot yet obtainedPending (12–18 months)
MySuper complianceDefault option must meet MySuper requirementsNot yet implementedPending
Member outcome assessmentsAnnual assessment of member outcomesNot yet implementedPending
Cooling-off (s1019B Corporations Act)14 days from confirmation or 5th business dayCoolingOffNotice (super variant)Implemented
PortabilityMembers can transfer their balanceSwitch request generator for super rolloversImplemented

APRA Prudential Standards

11. Electronic Transactions Act 1999

Provides legal validity for electronic communications and contracts. Key provisions for the app:

ProvisionDescriptionApp ImplementationStatus
s8 — Validity of electronic transactionsElectronic form is valid if parties consentDigital application and acceptance flowImplemented
s9 — Writing requirement satisfied electronicallyElectronic text satisfies writing requirementsAll disclosures rendered as accessible textImplemented
s10 — Signature requirementElectronic signature acceptable with consentCheckbox acceptance as electronic consentPartial — may need stronger e-signature
s14A — Time and place of dispatch/receiptElectronic record deemed received when accessibleIn-app display at point of needImplemented

12. Consumer Data Right (CDR) / Open Banking

Regulated under Part IVD of the Competition and Consumer Act 2010, administered by ACCC. Good Money uses Basiq as an intermediary for Open Banking access.

RequirementDescriptionApp ImplementationStatus
CDR AccreditationRequired for direct access to consumer banking dataUsing Basiq as accredited intermediary (ADI-level)Implemented via Basiq
Consumer consentExplicit, informed, and specific consent requiredBasiq consent flow with redirect to secure consent pageImplemented
Data minimisationOnly collect data necessary for stated purposeBasiq scoped to accounts, balances, transactionsImplemented
Consent duration and withdrawalConsumer can withdraw consent at any timeDisconnect function for bank connectionsImplemented
Data retention limitsData must be deleted when no longer neededNot yet implemented — requires data lifecycle policyPending

13. Anti-Hawking Provisions

Section 992A of the Corporations Act prohibits unsolicited offers of financial products. The 2021 reforms (Treasury Laws Amendment (Design and Distribution Obligations and Product Intervention Powers) Act 2019) strengthened these provisions.

RequirementApp ImplementationStatus
No unsolicited offers of financial productsProducts only shown when user navigates to product sections (user-initiated)Implemented
Clear indication that viewing is user-initiated"You have chosen to view these products" text on all marketplace sectionsImplemented
No cold-call sales of financial productsNo outbound sales featuresCompliant
Push notification restrictionsNo product-specific push notifications implementedCompliant
Gamification Consideration: Happy Cash/Good Cash incentives linked to product applications could be scrutinised under anti-hawking if they constitute "inducement" to acquire financial products. Ensure incentives reward engagement/education rather than product acquisition specifically. The current design awards cash for completing applications (process) rather than for purchasing products (outcome).

14. Best Interest Duty — Financial Advice

Section 961B of the Corporations Act requires financial advisers to act in the best interest of the client when providing personal advice. The Levy Review (Quality of Advice Review) is expected to create new categories of "qualified advice" with lighter obligations.

General Advice vs Personal Advice

TypeDefinitionApp ApproachObligations
General AdviceDoes not consider personal circumstancesProduct comparisons, rate displays, educational contentGeneral Advice Warning required
Personal AdviceConsiders personal objectives, situation, needs"Best for you" recommendations based on user's financial dataBest Interest Duty, SoA, appropriate advice
Critical Risk: The app's recommendation engine uses personal financial data (from Fact Find and Open Banking) to generate personalised product recommendations with "Best for You" tags. This likely constitutes personal advice under s766B(3), triggering the full Best Interest Duty. Mitigations:

1. Frame all recommendations as general advice with appropriate warnings (current approach)
2. Ensure recommendation engine does not consider individual circumstances beyond product features
3. If personal advice, require human-reviewed Statement of Advice (SoA) before product acquisition
4. Monitor Levy Review outcomes for "qualified advice" pathway

App Implementation — Best Interest Framework

FeatureImplementationStatus
Best Interest scoringProductContext scores products; only recommends when score ≥ 65 + 2+ reasonsImplemented
Audit trailRecommendationAuditEntry with timestamp, reasons, comparison detailsImplemented
"Why we recommend this" transparencyExpandable audit trail on each product cardImplemented
General Advice WarningProminent amber warning on all recommendation screensImplemented
Statement of Advice (SoA)Not yet implemented — required if providing personal advicePending

15. Dual-Currency (Happy Cash / Good Cash) Compliance

The Happy Cash / Good Cash system mirrors VGW's Gold Coin / Sweeps Coin architecture. Key regulatory considerations:

RiskDescriptionMitigationStatus
Deposit-TakingIf ASIC/APRA determines Happy Cash constitute deposit-taking, an ADI licence is requiredHappy Cash are prepaid service credits with no cash redemption — not deposits. Good Cash has expiry (12 months), variable rates, multiple earning triggersRequires legal opinion
Stored Value FacilityASIC may classify as a stored value facility under the Payment Systems (Regulation) Act 1998Good Cash can only be redeemed against Good Money product costs (mortgage, insurance, super) — not converted to cashRequires legal opinion
Financial ProductIf Happy Cash is classified as a financial product, AFSL authorisation is needed for dealingStructured as loyalty/rewards program, not an investment or payment instrumentRequires legal opinion
Gift Card RegulationsAustralian Consumer Law gift card provisions (3-year minimum expiry)Good Cash has 12-month expiry — this may need to be extended to 3 years if classified as a gift cardRequires legal review
GST TreatmentPurchase of Happy Cash may be a taxable supply under the GST ActSeek ATO private ruling on GST treatment of coin purchases and cash redemptionsPending
SWOT v2 — Threat T1: Regulatory reclassification of the dual-currency model is the most consequential risk. ASIC pre-application meeting and formal legal opinion from a top-tier firm (KWM, Allens, Herbert Smith Freehills) should be obtained before commercial launch. Plan B: operate without dual-currency as a standalone manufacturing fintech at $400M+ EBITDA.

16. App Feature Compliance Matrix

App FeatureApplicable LawsRequired DisclosuresStatus
Product Marketplace CardsCorporations Act s949A, s992A; DDOGeneral Advice Warning, PDS/TMD/FSG links, anti-hawking textImplemented
Product Application FormCorporations Act Part 7.9; NCCP (mortgage); Privacy Act APP 5PDS, Credit Guide (mortgage), KFS (mortgage), Privacy Notice, T&C acceptance, TMD acknowledgment, Cooling-offImplemented
Mortgage TabNCCP Act; Corporations Act Schedule 2Comparison rate warning, calculation estimates disclaimerImplemented
Insurance TabInsurance Contracts Act 1984; Corporations Act Part 7.9PDS reference, coverage summary disclaimerImplemented
Superannuation TabSIS Act 1993; Corporations Act Part 7.9Past performance warning, projection assumptions disclosureImplemented
Budget / Savings TabCorporations Act Part 7.9; NCCP (for savings accounts)Estimates disclaimerImplemented
Health Data IntegrationPrivacy Act 1988 (sensitive information); ICA 1984Explicit consent, purpose limitation, disconnect rightsImplemented
Open Banking (Basiq)CDR Rules; Competition and Consumer Act Part IVDCDR consent flow, data minimisationImplemented
Happy Cash / Good CashCorporations Act; Payment Systems Act; ACL; GST ActTerms of use, expiry disclosure, non-redeemable for cashRequires legal opinion
Financial Advice / RecommendationsCorporations Act s961B, s766BGeneral Advice Warning; potentially SoA if personal adviceGeneral advice framing — review needed
Investor Risk ProfileCorporations Act s945A (appropriate advice)General advice disclaimer presentImplemented
Settings / AboutCorporations Act s912D; NCCP s27AFSL/ACL number, AFCA membership, dispute resolutionPlaceholder — awaiting licences

17. Pre-Launch Regulatory Checklist

Critical Path Items (Must Complete Before Launch)

#ActionOwnerTimelineStatus
1Obtain AFSL (or register as CAR of licensed entity)CEO / Legal4–12 monthsPending
2Obtain ACL for credit productsCEO / Legal3–8 monthsPending
3Register with AUSTRACCompliance1–2 monthsPending
4Join AFCA as EDR memberCompliance1 monthPending
5Obtain Professional Indemnity insuranceCEO / Legal1–2 monthsPending
6Appoint Responsible Manager(s) meeting RG 105CEOOngoingPending
7Prepare and publish PDS documents for each productLegal / Product2–3 monthsPending
8Prepare and publish TMD for each productLegal / Product2–3 monthsPending
9Prepare and publish FSGLegal1–2 monthsPending
10Prepare Credit Guide and Key Facts SheetsLegal / Product1–2 monthsPending
11Obtain legal opinion on Happy Cash / Good Cash classificationCEO / Legal (KWM/Allens)1–2 monthsPending
12ASIC pre-application meeting for dual-currency modelCEO / Legal1–3 monthsPending
13Implement KYC/AML identity verificationEngineering2–3 monthsPending
14Implement formal unsuitability assessment for creditEngineering1–2 monthsPending
15Hire Chief Actuary (insurance underwriting)CEO2–4 monthsPending
16SOC 2 Type II certificationCTO / CISO6–12 monthsPending
17CPS 234 Information Security complianceCISO3–6 monthsPending
18Update placeholder licence numbers, ABN, AFCA membership in appEngineeringWhen obtainedPlaceholder
19Host PDS/FSG/TMD/Credit Guide PDFs at document URLsEngineering / LegalWhen preparedPlaceholder URLs
20Implement personalised Key Facts Sheet generationEngineering1–2 monthsPending

Items Already Implemented in App