File one: the deposit from a stranger
Mei is buying her first home. She tells you her cousin will send the deposit and the cash to complete from overseas, and that you will see a transfer from a company name you do not recognise. She is relaxed about it, and in a hurry.
AUSTRAC’s Operation Claw found offshore or third-party funds used for settlements or mortgage repayments. That does not make Mei a criminal. It does mean the source of the money is part of the file, not a detail to skip.
The right move: ask who is sending the money and why, ask for evidence that fits the explanation, and write down the answer. If you cannot explain the source to your licensee in a couple of sentences, tell your licensee before you submit.
Remember
- Third-party and offshore funds need an explanation on file.
- Ask early, in writing, and keep the answer.
- If you cannot explain it simply, tell your licensee.
Facts and sources for this part
- The same work found offshore or third-party funds used for settlements or mortgage repayments, and the repeated use of the same brokers, accountants or law firms across applications. [S8]
File two: payslips from a company that exists only on paper
A referral partner sends you three applications in a week. Each borrower has a payslip from a different “consulting” company, each payslip shows income much greater than the borrower’s lifestyle suggests, and each employer letter has the same phone number.
ASIC’s Sydney case involved false employer letters or payslips, companies the customers did not work for, and income figures much greater than their real incomes. Repeated use of the same referrer across applications is also a pattern AUSTRAC says lenders look for.
The right move: stop, do not submit, and keep all three files and the referral emails. Check the employers through sources you find yourself. Then tell your licensee that you have a pattern you cannot explain.
Remember
- Three files with one shared phone number is a pattern, not a coincidence.
- Verify employers independently.
- Report the pattern before you submit anything.
Facts and sources for this part
- ASIC permanently banned three Sydney mortgage brokers over false employer letters or payslips given to a bank to support 21 home loan applications; the bank financed over $17M of loans in reliance on false documentation. [S10]
- In that case the customers were not employed by the companies named in the letters, and the payslips showed income much greater than their real incomes. [S10]
- The same work found offshore or third-party funds used for settlements or mortgage repayments, and the repeated use of the same brokers, accountants or law firms across applications. [S8]
File three: the conveyancer’s new account
Two days before settlement, a client forwards you an email from “her conveyancer” with a new trust account and the words “urgent, old account closed”. The email address is one letter different from the real firm’s.
This is the pattern the Australian Cyber Security Centre warns about: someone impersonating a party to the deal and inserting new bank details for a settlement payment. The advice is to confirm any change by calling the sender’s established phone number, or meeting them face to face, before transferring any funds.
The right move: ring the conveyancer on a number from your own records, tell the client not to pay yet, and let the conveyancer confirm in a way you can trust. If the details are false, tell the conveyancer, your licensee and the client straight away.
Remember
- One letter different is still a different address.
- Stop the client paying until the call is done.
- Tell everyone once you know it is false.
Facts and sources for this part
- The Australian Cyber Security Centre warns that criminals impersonate parties to a property transaction, such as real estate agents or conveyancers, and insert illegitimate bank details for settlement or rental payments. [S11]
- If any party to a property transaction says their bank details have changed, confirm it by calling the sender’s established phone number, or meeting them face to face, before transferring any funds. [S11]
File four: the second job that does not quite fit
A borrower, Jacinta, has a genuine full-time job and genuine bank statements. She also lists a second job at a café with a payslip that shows regular pay, yet her statements show only small, irregular deposits that do not match it.
AUSTRAC describes wage staging: one employer and income may be genuine, but a second job or income stream is staged to boost loan eligibility, and genuine bank statements can make it harder to detect.
The right move: ask Jacinta to explain the difference between the payslip and the deposits, and ask for something independent, such as a tax record. If the story changes or she cannot explain it, do not include the second income, and talk to your licensee.
Remember
- A payslip that does not match deposits needs an explanation.
- Genuine statements can still sit next to a staged income.
- Leave out income you cannot support.
Facts and sources for this part
- AUSTRAC describes wage staging: one employer and income may be genuine, but a second job or income stream is staged to boost loan eligibility, and the bank statements supplied may not have been falsified, which makes it harder to detect. [S13]
- Lenders reported spotting falsified payslips and statements through inconsistencies in fonts and errors in the gross, net, tax and superannuation amounts, and false or old employer details. [S13]
Check what you have learned
Three questions from the test, each explained. Tap an answer.
Question 1 of 3
Three applications in a week come from the same referrer, each with a payslip from a different small company. What is the best response?
Show the answer
Right answer: B, Do not submit, keep the files and tell your licensee about the pattern. Repeated use of the same brokers, accountants or other third parties across applications is a pattern regulators describe. [S8]
Question 2 of 3
What should you tell the client who is about to pay the new account?
Show the answer
Right answer: B, Wait until the conveyancer is confirmed by phone on a trusted number. Confirm changes by calling the sender’s established phone number, or meeting them face to face, before transferring funds. [S11]
Question 3 of 3
You cannot explain a file’s story to your licensee in a couple of sentences. What does AUSTRAC’s advice about timing suggest?
Show the answer
Right answer: D, Raise it before submission, because it is hardest to fix once funds have moved. The most effective way to stop mortgage fraud is before a loan is granted; once the funds have moved, recovery is significantly harder. [S8]