RESPONSIBLE LENDING POLICY

Version 2.0 | August 2026

1. INTRODUCTION AND SCOPE

1.1 This Responsible Lending Policy (“Policy”) sets out the responsible lending framework adopted by Pod 3 Finance Pty Ltd ABN: 55 661 632 702 T/A Quickzy Finance (“QUICKZY”, “we”, “us”, “our”). The purpose of this Policy is to ensure that QUICKZY meets its obligations under the responsible lending provisions of the National Consumer Credit Protection Act 2009 (Cth) and related legislation, and that all credit activities undertaken by or on behalf of QUICKZY are conducted in a manner that protects consumers from entering into credit contracts or consumer leases that are unsuitable for their needs, objectives, or financial circumstances.

1.2 This Policy is designed to comply with:
(a) the National Consumer Credit Protection Act 2009 (Cth) (“NCCP Act”), including the National Credit Code (Schedule 1);
(b) the National Consumer Credit Protection Regulations 2010 (Cth);
(c) ASIC Regulatory Guide 209: Credit licensing: Responsible lending conduct (“RG 209”) (as updated March 2025); and
(d) all other applicable Australian consumer credit legislation and regulatory guidance.

1.3 QUICKZY’s entity details are as follows:
(a) Full name: Pod 3 Finance Pty Ltd
(b) ABN: 55 661 632 702
(c) Trading as: Quickzy Finance
(d) Australian Credit Licence (ACL) Number: 544927
(e) Authorised credit activities:
(i) credit provider of consumer loans;
(ii) credit assistance for consumer loans;
(iii) mortgagee under mortgage securing consumer credit contracts;
(iv) consumer leases; and
(v) credit assistance for consumer leases.

1.4 QUICKZY currently provides secured personal medium amount credit contracts (MACCs) within the scope of its licensed activities.

1.5 This Policy applies to all QUICKZY staff, representatives, and authorised credit representatives, and to all credit activities undertaken by or on behalf of QUICKZY.

1.6 This Policy should be read together with QUICKZY’s Privacy and Credit Reporting Policy, QUICKZY’s Privacy Collection Notice and Consent; QUICKZY’s Supplementary Hardship Privacy Policy; and QUICKZY’s Complaints and Dispute Resolution Policy.

1.7 This Policy was last updated in July 2026. This is Version 2.0.

2. LEGISLATIVE FRAMEWORK

2.1 The NCCP Act establishes the regulatory framework for consumer credit in Australia. Chapter 3 of the NCCP Act contains the responsible lending conduct obligations that apply to licensees, including credit providers and credit assistance providers.

2.2 The National Credit Code, contained in Schedule 1 to the NCCP Act, governs the terms and conditions of credit contracts and consumer leases, including disclosure requirements, interest and fee limits, enforcement provisions, and hardship provisions.

2.3 The key statutory provisions governing QUICKZY’s responsible lending obligations are as follows:

- (a) Section 128 — Obligation to assess unsuitability: A licensee must not enter into a credit contract with a consumer, or increase a credit limit, unless the licensee has, within 90 days before the credit day:
  - (i) made an assessment in accordance with s 129 that the contract is not unsuitable for the consumer; and
  - (ii) made the inquiries and verification required by s 130.
  Civil penalty: 5,000 penalty units.
- (b) Section 129 — Assessment of unsuitability: The assessment must specify the period it covers and assess whether the credit contract will be unsuitable for the consumer if it is entered into or the credit limit is increased.
- (c) Section 130 — Reasonable inquiries: The licensee must, before making an assessment:
  - (i) make reasonable inquiries about the consumer’s requirements and objectives in relation to the credit contract (s 130(1)(a));
  - (ii) make reasonable inquiries about the consumer’s financial situation (s 130(1)(b));
  - (iii) take reasonable steps to verify the consumer’s financial situation (s 130(1)(c)).
- (d) Section 131 — When a credit contract must be assessed as unsuitable: The contract will be unsuitable if, at the time of the assessment, it is likely that:
  - (i) the consumer will be unable to comply with their financial obligations under the contract, or could only comply with substantial hardship (s 131(2)(a));
  - (ii) the contract will not meet the consumer’s requirements or objectives (s 131(2)(b));
  - (iii) prescribed regulatory circumstances apply (s 131(2)(c)).
  Section 131(3) provides a presumption: if the consumer could only comply with their financial obligations by selling their principal place of residence, it is presumed the consumer could only comply with substantial hardship, unless the contrary is proved.
- (e) Section 132 — Giving the consumer the assessment: The licensee must, if requested by the consumer, provide a written copy of the assessment within the following timeframes:
  - (i) if requested before entering the contract — before the contract is entered into;
  - (ii) if requested within 2 years of the credit day — within 7 business days of the request; and
  - (iii) if requested between 2 and 7 years after the credit day — within 21 business days of the request.
  The licensee must not charge the consumer any fee for providing a copy of the assessment (s 132(4)). Civil penalty: 5,000 penalty units.
- (f) Section 133 — Prohibition on entering unsuitable credit contracts: QUICKZY must not enter into a credit contract with a consumer, or increase a credit limit, if the contract is unsuitable for the consumer. A credit contract is unsuitable if, at the time of the assessment, it is likely that: (i) the consumer will be unable to comply with their financial obligations or could only comply with substantial hardship; (ii) the contract will not meet the consumer’s requirements or objectives; or (iii) prescribed regulatory circumstances apply (s 133(2)). Civil penalty: 5,000 penalty units.

2.4 Consumer leases. Parallel responsible lending obligations under Part 3-4 of the NCCP Act (ss 151–156) apply to consumer leases. QUICKZY must conduct equivalent assessments for consumer leases, including:

(a) obligation to assess unsuitability (s 151);
(b) assessment of unsuitability (s 152);
(c) reasonable inquiries (s 153);
(d) when the lease must be assessed as unsuitable (s 154);
(e) giving the consumer the assessment (s 155); and
(f) prohibition on entering unsuitable leases (s 156).

2.5 ASIC Regulatory Guide 209 (RG 209). RG 209 sets out ASIC’s views on the responsible lending obligations under the NCCP Act. QUICKZY will have regard to RG 209 guidance, including:

(a) the scalable nature of inquiry obligations, whereby the level and extent of inquiries and verification are proportionate to the risk of the credit product being unsuitable;
(b) the four guiding principles: (i) the purpose of the obligation; (ii) the individual consumer’s circumstances; (iii) the risk of harm if the product is unsuitable; and (iv) the broader professional and regulatory environment; and
(c) the March 2025 update regarding the treatment of HELP debts in lending assessments.

2.6 General conduct obligations. QUICKZY must also comply with ss 47(1) and 48 of the NCCP Act (general conduct obligations for licensees), including the obligation to do all things necessary to ensure that credit activities authorised by its licence are engaged in efficiently, honestly, and fairly.

3. RESPONSIBLE LENDING OBLIGATIONS — OVERVIEW

3.1 QUICKZY adopts a three-pillar assessment framework for responsible lending:

(a) assessing the suitability of the consumer in line with QUICKZY’s Credit Policy;
(b) assessing the consumer’s capacity to repay the proposed credit without substantial hardship; and
(c) assessing that the credit contract or consumer lease will not be unsuitable for the consumer.

3.2 It is illegal for a credit provider to enter into, or extend, credit that is unsuitable for a consumer’s needs and financial capacity, or that does not meet the consumer’s requirements and objectives (s 133, NCCP Act).

3.3 QUICKZY will only provide credit where, based on the available information obtained through reasonable inquiries and verified through reasonable steps, the consumer can reasonably afford to repay the credit extended.

3.4 Applicants are expected to provide honest and accurate information. QUICKZY’s assessment is based on information provided by the consumer, verified by QUICKZY, and any other information QUICKZY has reason to believe is true (s 131(4), NCCP Act).

4. Pre-Assessment Requirements

4.1 Before conducting a responsible lending assessment, QUICKZY must provide the consumer with a Credit Guide when it becomes apparent that the consumer wishes to enter into a credit contract (s 126, NCCP Act).

4.2 The consumer must be provided with, and acknowledge, QUICKZY’s Privacy Collection Notice and Consent in accordance with the Privacy Act 1988 (Cth) and QUICKZY’s Privacy and Credit Reporting Policy.

4.3 A formal loan application with supporting documentation must be received from the consumer before the assessment commences.

4.4 Pre-contractual disclosure. Before a consumer enters into a credit contract, QUICKZY must provide:

(a) a pre-contractual statement disclosing the credit provider name, amount of credit, repayments and frequency, calculation of charges, enforcement expenses, total amount payable, and credit fees and charges; and
(b) an Information Statement in the form required by the NCCP Regulations (Form 5: Things You Should Know About Your Proposed Credit Contract).

5. REASONABLE INQUIRIES (s 130, NCCP Act)

5.1 QUICKZY must make reasonable inquiries about the consumer before making an assessment. These inquiries must be completed within 90 days before the credit day (s 128).

5.2 Inquiries about requirements and objectives (s 130(1)(a)). QUICKZY will inquire into:

(a) the nature and purpose of the credit sought;
(b) the consumer’s stated objectives and the relative importance of each;
(c) the term of the credit relative to the useful life of any asset acquired;
(d) the consumer’s understanding of the product; and
(e) any other relevant matter.

5.3 Inquiries about financial situation (s 130(1)(b)). QUICKZY will inquire into:

(a) the source and amount of all gross income, including employment income, government benefits, rental income, investment income, and any other income;
(b) employment status and stability;
(c) assets;
(d) expenses and financial commitments, including rent, utilities, groceries, insurance, existing debt repayments, child support, HELP/student loan repayments, and other regular outgoings; and
(e) any other liabilities or contingent liabilities.

5.4 Scalable approach. Consistent with RG 209, the level and extent of QUICKZY’s inquiries will be proportionate to the risk of the credit product being unsuitable for the individual consumer. Factors QUICKZY will consider include:

(a) the amount and term of the credit;
(b) the nature and complexity of the product;
(c) the consumer’s circumstances; and
(d) any indicators of potential vulnerability or financial stress.

5.5 HELP debt treatment. In accordance with the March 2025 update to RG 209, QUICKZY will have regard to the nature of HELP and other student loan repayments — which are income-contingent and differ from other forms of debt — when assessing a consumer’s financial situation.

6. Verification (s 130(1)(c), NCCP Act)

6.1 QUICKZY must take reasonable steps to verify the consumer’s financial situation before making an assessment.

6.2 Minimum verification requirements. For all applications, QUICKZY will obtain and consider:

(a) bank statements covering at least the preceding 90 days, showing all transactions and balances;
(b) payroll or salary verification, cross‑checked against actual hours worked and salary on a year‑to‑date basis;
(c) for self‑employed applicants, a recent tax return and a letter from a qualified accountant detailing the consumer’s financial position, subject to the following provisions: Where their tax returns have not yet been lodged, the applicant’s income will be based on the salary or business income credited into their bank account over the previous 90 days. In addition, their business expenses will be verified with the applicant to determine their net income;
(d) a credit history report from one or more Credit Reporting Bodies; provided that returning customers will only be subject to a credit check when reasonably necessary to ensure that the information relied upon in QUICKZY’s lending assessment is accurate, up‑to‑date and complete, in accordance with ASIC’s responsible lending expectations and the Privacy Act 1988 (Cth). A credit check will be conducted for new applicants, and may also be conducted for returning customers where the previous credit information is no longer reasonably current, where there is an indication that the customer’s financial circumstances may have changed, or where additional verification is required to ensure the loan remains affordable and suitable. QUICKZY will only obtain credit reports when they are required for the purpose of assessing an application or verifying a customer’s financial situation, and will not conduct credit checks where they are not reasonably necessary for these purposes; and
(e) any other documents or information reasonably necessary to verify the consumer’s financial situation.

6.3 Income from government benefits. Where a consumer’s income includes government benefits (such as Centrelink payments), QUICKZY will verify the type, amount, and duration of those benefits.

6.4 Variable, seasonal, or irregular income. Where a consumer’s income is variable, seasonal, or irregular, QUICKZY will take additional steps to assess the sustainability of that income over the term of the proposed credit.

6.5 Expense verification. QUICKZY will not rely solely on the consumer’s self-reported expenses. QUICKZY will cross-check declared expenses against bank statement data.

6.6 Independent verification of broker-supplied information. Where a loan application is referred by a broker or introducer, QUICKZY will independently verify all information supplied by the referring party. QUICKZY will not rely solely on a broker’s assessment or documentation without conducting its own inquiries and verification.

7. Assessment of Unsuitability (ss 129, 131, NCCP Act)

7.1 QUICKZY must make a final assessment, in writing, as to whether the proposed credit contract is “not unsuitable” for the consumer (s 129).

7.2 A credit contract must be assessed as unsuitable if, at the time of the assessment, it is likely that:

(a) the consumer will be unable to comply with their financial obligations under the contract, or could only comply with substantial hardship (s 131(2)(a));
(b) the contract will not meet the consumer’s requirements or objectives (s 131(2)(b)); or
(c) prescribed regulatory circumstances apply (s 131(2)(c)).

7.3 Presumption of substantial hardship. If the consumer could only comply with their financial obligations by selling their principal place of residence, it is presumed the consumer could only comply with substantial hardship unless the contrary is proved (s 131(3)).

7.4 Information used in assessment. Only information that satisfies both of the following conditions may be taken into account:

(a) the information relates to the consumer’s financial situation, requirements, or objectives; and
(b) at the time of the assessment, QUICKZY had reason to believe the information was true, or would have had reason to believe it was true had QUICKZY made the required inquiries and verification (s 131(4)).

7.5 QUICKZY will not enter into a credit contract with a consumer, or increase a credit limit, if the contract is assessed as unsuitable (s 133).

8. Affordability Assessment

8.1 QUICKZY will assess the consumer’s capacity to repay the proposed credit without substantial hardship by considering all relevant factors, including:

(a) surplus income after expenses and proposed repayment;
(b) source, consistency, and reliability of income;
(c) living expenses and fluctuations due to circumstances;
(d) all existing debt repayments and financial commitments, including child support and HELP debts;
(e) the likelihood of a forced sale of assets to meet repayments; and
(f) any other relevant information obtained.

8.2 Surplus requirement. A surplus of at least 10% of net income must be evident after taking into account all living expenses, rent or mortgage payments, groceries, and all other financial and non-financial commitments.

8.3 QUICKZY’s six fundamental assessment criteria. QUICKZY applies the following six criteria in every affordability assessment:

(1) Period of employment;
(2) Affordability;
(3) Credit history (subject to clause 6.2(d) above);
(4) Previous loan history;
(5) Commitment level / protected earnings amount; and
(6) Banking history.

9. Requirements and Objectives Assessment

9.1 QUICKZY must assess whether the credit contract meets the consumer’s requirements and objectives.

9.2 Factors QUICKZY will consider include:

(a) the nature of the credit requested and the consumer’s stated objectives;
(b) the relative importance of each objective where there are multiple objectives;
(c) the term of the credit relative to the useful life of any asset acquired with the credit;
(d) the fees and charges applicable to the proposed credit contract;
(e) the consumer’s understanding of the product and its risks; and
(f) any other relevant matter.

9.3 QUICKZY will document the consumer’s stated requirements and objectives as part of the loan application process.

10. Consumer Leases

10.1 If QUICKZY enters into a consumer lease, the responsible lending obligations under Part 3-4 of the NCCP Act (ss 151–156) will apply.

10.2 QUICKZY will conduct the same standard of reasonable inquiries, verification, and assessment for consumer leases as for credit contracts, adapted as necessary for the different structure of a lease arrangement.

10.3 A consumer lease must be assessed as unsuitable if, at the time of the assessment, it is likely that:

(a) the consumer will be unable to comply with their financial obligations under the lease, or could only comply with substantial hardship;
(b) the lease will not meet the consumer’s requirements or objectives; or
(c) prescribed regulatory circumstances apply (s 154(2)).

10.4 Note: QUICKZY does not currently provide consumer leases.

11. Loan Processing Procedure

11.1 Each new loan application, whether for an existing or new customer, must be assessed as a new application. Each application must go through the complete process of: Identify, Verify, Assess, and Determine.

11.2 Step 1 — Identify.

(a) Each applicant must complete an Application Form containing all necessary Privacy Act, Credit Reporting, and related consents.
(b) Each applicant must be identified using a 100-point identification system. Documents must provide proof of full legal name, date of birth, current address, bank account, and income.
(c) Staff must check expiry dates and banking details and update where necessary.
(d) Reasonable inquiries into the consumer’s financial situation, requirements, and objectives commence at this stage.

11.3 Step 2 — Verify.

(a) Both new and repeat customers must provide proof of income (pay slip, bank statement, or other acceptable documentation).
(b) Where bank statements are provided, the frequency of payments must be checked to ensure employment is ongoing and income is regular.
(c) Verification documents must be uploaded to the customer record for every loan.
(d) If the income source has changed, employment verification must be conducted by contacting the new employer.

11.4 Step 3 — Assess.

(a) Staff must make file notes regarding any alterations that support a lending decision.
(b) Staff must gather enough information to reasonably foresee that the consumer can meet their obligations during the repayment period.
(c) Each case is assessed on its merits — staff must not merely follow a “check box” approach.
(d) The consumer’s requirements and objectives must be satisfied by a product assessed as “not unsuitable”.

11.5 Step 4 — Determine.

(a) Following identification, verification, and assessment, QUICKZY must make a determination as to the suitability of the product.
(b) The responsible officer must be reasonably satisfied that the consumer can meet repayments comfortably, that the product meets their needs and objectives, and that the credit is “not unsuitable” for the consumer.

12. Providing the Assessment to the Consumer (s 132, NCCP Act)

12.1 If a consumer requests a copy of the final assessment before entering the credit contract or increasing a credit limit, QUICKZY must provide a written copy before the contract is entered into or the limit is increased (s 132(1)).

12.2 If a consumer requests a copy after entering the credit contract:

(a) Within 2 years of the credit day — QUICKZY must provide a written copy within 7 business days of receiving the request (s 132(2)(c)).
(b) Between 2 and 7 years after the credit day — QUICKZY must provide a written copy within 21 business days of receiving the request (s 132(2)(d)).

12.3 QUICKZY must not charge any fee for providing a copy of the assessment (s 132(4)). Civil penalty: 5,000 penalty units.

13. Broker and Introducer Referrals

13.1 Where a loan application is referred by a broker, introducer, or other third party, QUICKZY will independently verify and confirm all information supplied by the referring party.

13.2 QUICKZY will not rely solely on a broker’s assessment or supporting documentation. QUICKZY’s own responsible lending assessment must be completed in full.

13.3 QUICKZY will ensure that all brokers and introducers acting on its behalf are appropriately licensed or authorised and comply with the responsible lending obligations under the NCCP Act.

14. Financial Hardship

14.1 Where a borrower experiences financial hardship, QUICKZY will consider applications for hardship variations in accordance with Part 4 of the National Credit Code (ss 72–75, Schedule 1 to the NCCP Act).

14.2 Hardship applications are to be referred to QUICKZY’s Hardship Officer, who will review the borrower’s financial position and determine the most appropriate resolution, having regard to:

(a) leaving the borrower in the best possible financial position; and
(b) protecting the legitimate interests of QUICKZY.

14.3 QUICKZY will handle hardship applications in accordance with QUICKZY’s Hardship Policy and the requirements of ASIC Regulatory Guide 271 (RG 271).

14.4 Privacy obligations relating to hardship applications, including the collection of sensitive information and the mandatory reporting of financial hardship information to Credit Reporting Bodies, are addressed in QUICKZY’s Privacy and Credit Reporting Policy and the Supplementary Hardship Privacy Policy.

15. Record-Keeping

15.1 QUICKZY must maintain adequate records of all responsible lending assessments, inquiries, verification steps, and determinations.

15.2 Records must include:

(a) the consumer’s application and supporting documentation;
(b) evidence of all inquiries made about the consumer’s requirements, objectives, and financial situation;
(c) evidence of all verification steps taken;
(d) the written assessment of unsuitability (or “not unsuitability”);
(e) file notes documenting the rationale for lending decisions; and
(f) copies of all documents provided to the consumer, including the Credit Guide, pre-contractual disclosure, Information Statement, and assessment copy (if requested).

15.3 Records must be retained for at least 7 years after the credit contract is entered into or the credit limit is increased, to ensure QUICKZY can comply with its obligation to provide assessment copies under s 132(2) of the NCCP Act.

15.4 Records must be stored securely and in a manner that enables retrieval within the timeframes required by the NCCP Act.

16. Staff Training and Competency

16.1 All QUICKZY staff, representatives, and authorised credit representatives who are involved in credit activities must be trained in QUICKZY’s responsible lending obligations and this Policy.

16.2 Training must cover:

(a) the statutory obligations under Chapter 3 of the NCCP Act;
(b) QUICKZY’s internal policies and procedures for responsible lending;
(c) how to make reasonable inquiries and conduct verification;
(d) how to assess unsuitability;
(e) identifying indicators of potential consumer vulnerability or financial stress;
(f) QUICKZY’s obligations regarding hardship; and
(g) record-keeping requirements.

16.3 Training must be provided at induction and refreshed at least annually, or whenever there are material changes to the law or QUICKZY’s policies.

16.4 QUICKZY will maintain records of all training provided, including the date, content, and attendees.

17. Compliance Monitoring and Review

17.1 QUICKZY’s Compliance Officer (or equivalent) is responsible for monitoring compliance with this Policy and the responsible lending obligations under the NCCP Act.

17.2 QUICKZY will conduct periodic reviews of loan files and assessments to ensure compliance with this Policy and the NCCP Act.

17.3 Any identified breaches of this Policy or the NCCP Act must be reported to QUICKZY’s Compliance Officer and, where required, to ASIC in accordance with s 50A of the NCCP Act (breach reporting obligations).

17.4 This Policy will be reviewed at least annually, or sooner if there are material changes to the applicable legislation, ASIC regulatory guidance, or QUICKZY’s business practices.

18. Consequences of Non-Compliance

18.1 Failure to comply with the responsible lending obligations under the NCCP Act may result in:

(a) civil penalties of up to 5,000 penalty units per contravention (ss 128, 131, 132, 133);
(b) criminal penalties for strict liability offences (s 132(5));
(c) ASIC enforcement action, including banning orders, licence conditions, or licence suspension or cancellation;
(d) compensation orders; and
(e) reputational damage to QUICKZY.

18.2 Internal breaches of this Policy may result in disciplinary action, including termination of employment or engagement.

19. Related Policies and Documents

19.1 This Policy should be read together with:

(a) QUICKZY Privacy and Credit Reporting Policy (Version 2.0, July 2026);
(b) QUICKZY Privacy Collection Notice and Consent;
(c) QUICKZY Supplementary Hardship Privacy Policy;
(d) QUICKZY Complaints and Dispute Resolution Policy.

20. Contact

20.1 Questions about this Policy should be directed to:

Phone: 1300 243 191
Email: care@quickzy.com.au
Address: PO Box 331, Kellyville, NSW 2155
Website: https://quickzy.com.au/

Version 2.0 | July 2026 | Pod 3 Finance Pty Ltd T/A Quickzy Finance