Credit Conduct
Credit conduct covers two distinct but related assessments: the formal credit file (what the credit reporting bureaus hold) and the bank statement review (what the borrower's actual transaction accounts reveal about spending and repayment behaviour).
Core Assessment Analysis
How Lenders Assess Credit Conduct
Credit conduct assessment is not limited to a credit score. Lenders examine both the formal credit file held by credit reporting bureaus and the borrower's actual transaction behaviour visible in 3–6 months of bank statements.
Comprehensive Credit Reporting (CCR)
Australia's Comprehensive Credit Reporting system means that credit files now contain positive as well as negative information. Where credit providers participate in CCR (which includes the major banks and many non-bank lenders), the following information appears on the credit file:
- Repayment history: monthly repayment status across all participating credit accounts — whether payments were on time, late, or missed
- Credit limits and balances: current and historical credit limits across credit cards and revolving facilities
- Account opening and closing history
- Credit enquiries: every formal credit application made in the last 5 years
- Defaults and serious credit infringements: unpaid accounts listed by creditors
- Court judgements: writs and summons related to debt
Under CCR, a borrower who has been consistently making minimum payments (without technically defaulting) may still have a repayment history pattern that raises lender concern — because the positive repayment data is now visible.
What lenders look for in the credit file
- Defaults: the presence, size, age, and paid/unpaid status of defaults
- Repayment history: any pattern of late or missed payments, even without a formal default
- Enquiry frequency: multiple credit applications over a short period can indicate financial stress or shopping around excessively
- Credit utilisation: consistently high balances relative to limits across credit cards
Bank statement conduct
Separately from the credit file, lenders review 3–6 months of primary transaction account statements. This review looks at spending patterns, income consistency, and financial behaviour indicators.
Factors that typically attract scrutiny during bank statement review:
- Gambling transactions: regular use of betting platforms, casinos, or gambling apps — even at moderate levels
- Overdraft usage: accounts regularly going below zero balance
- BNPL usage: multiple active BNPL facilities used frequently
- Unexplained cash withdrawals: large or regular cash withdrawals without obvious purpose
- Consistent account depletion: accounts falling to near zero within days of pay day
- Transfers to unidentified accounts: regular transfers that don't correspond to identifiable commitments
Practical preparation
For borrowers preparing to apply, 3–6 months of clean banking conduct before application is the standard guidance. This means:
- Avoiding gambling transactions entirely during the review period
- Maintaining positive account balances
- Reducing BNPL usage
- Avoiding multiple credit applications in the period before applying
Related pillar
Credit conduct sits within the Borrower Profile and Policy Sensitivity Pillar.
Why Underwriters Focus Here
CCR means lenders can now see repayment behaviour across the full credit system, not just defaults. Automated decisioning systems process CCR data alongside bank statement analysis — and patterns of late payment, overdrawing, or gambling activity visible in that data can affect approval outcomes even where the borrower has no formal defaults on their file. Lenders are assessing behavioural risk, not just default risk.
Key Outcome Assessment Factors
CCR repayment history codes (on-time, one month late, two months late, etc.), the number and frequency of credit enquiries in the preceding 12 months, whether any defaults or judgements are recorded, the age and paid/unpaid status of any defaults, and the content of 3–6 months of transaction account statements — particularly gambling, overdraft usage, and BNPL activity.
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General educational information only. Credit assessment policies vary between lenders. This content does not constitute credit advice. Credit files can be obtained from Equifax, Experian, and illion. Model Mortgages Pty Ltd | ACL 387460.
Model Mortgages Pty Ltd | Australian Credit Licence 387460
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