HAILO brings whole-of-debt modelling to BID files ahead of ASIC findings

Boilerplate reasons won’t pass, regulator says

HAILO brings whole-of-debt modelling to BID files ahead of ASIC findings

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ASIC is preparing to report on its first review of the mortgage broker best interests duty (BID), and it has warned that boilerplate reasons for recommendations will make compliance hard to prove.

LoanOptions.ai has now integrated debt analysis platform Unbound into its HAILO broker portal, which gives brokers a quantitative record to support the financial rationale behind a home loan recommendation.

The tool sits in the broker-facing backend of HAILO, LoanOptions.ai’s five-minute home loan application journey. Unbound models a client’s whole debt position, including mortgages, car loans, personal loans, credit cards and student loans, in a single analysis.

Australian mortgage brokers must act in their clients’ best interests when they provide credit assistance. Brokers can now draw on the client’s wider debt position when they structure and recommend a home loan.

The obligation now covers most new home lending in Australia. Brokers facilitated 81.6% of new residential home loans in the June 2026 quarter, up from 81% in March and 77.6% a year earlier, and settled $139.08 billion in new home loans.

Regulator sets the bar on recommendation reasons

ASIC commissioner Alan Kirkland told the MFAA National Conference in July that the review would be completed later this year.

He said brokers should document the reasons for their recommendations and explain them to customers, and that those reviewing recommendations should check the reasons make sense for the specific client.

Kirkland added that reasons built on “boilerplate factors that could apply to anyone” would make it hard to show a recommendation served that customer.

ASIC had already outlined its approach at the MFAA’s virtual Looking Ahead 2026 event in February, for which close to 3,000 brokers registered. The regulator said it was paying particular attention to the reasoning behind brokers’ lender and product choices.

At an MFAA webinar in March, Connective general counsel Daniel Oh said early feedback from the review showed explanations on many aggregator files were too generic when the cheapest option was not selected. REA Group general counsel Scott Stierli said the biggest risk was information held across multiple systems rather than in one central document.

From judgement call to mathematical record

Unbound gives brokers a quantitative, documented framework to support the financial rationale behind a recommendation. According to the companies, this turns what has traditionally relied on a broker’s qualitative judgement into a clear, auditable mathematical record.

The platform assesses how debts interact instead of treating each loan in isolation. Brokers and lenders can see how one refinancing decision might improve eligibility for another and where untapped opportunities sit.

The analysis often surfaces strategies to reduce repayments, reduce total interest, pay off debt faster, restructure existing lending, or finance a new asset or purchase.

Brokers can therefore assess existing loans alongside potential new lending, identify refinancing opportunities, evaluate different loan structures and build a clearer record that supports their advice.

Kirkland noted in July that acting in a customer’s best interests may mean explaining why the lowest interest rate does not automatically equal the cheapest or best-value loan.

Records in place of recollection

Julian Fayad, founder and CEO of LoanOptions.ai, said brokers already carry the responsibility of proving their advice is genuinely in a client’s best interest. However, he said most of their tools “only look at one loan in isolation”.

“Unbound lets us hand brokers a proper picture of a client’s whole debt position, right inside the HAILO workflow they’re already using, so the recommendation and the reasoning behind it are documented, not just remembered,” Fayad said.

He said the integration gives brokers “the same depth of analysis the big institutions have always had access to”.

He added that brokers “can spend less time justifying their advice and more time actually giving it”.

The analysis runs within the broker’s existing HAILO workflow and adds no friction to the customer-facing application.

Connective research released in March found 65% of brokers have no documented AI strategy and only 3% have formal policies for its safe use. The report also found many brokers experiment with AI in isolation rather than in end-to-end processes such as file notes and credit-policy checks.

Unbound’s entry into Australia

Paul Crowley, co-founder, CEO and CTO of Unbound, said most lending tools assess loans one by one, but borrowers do not manage their finances that way.

“Their mortgage, car loan, credit cards and personal loans all affect each other, and Unbound is built to analyse that whole picture together,” he said.

Crowley described LoanOptions.ai as the ideal way into Australia for Unbound and called it “an AI-native platform that brokers already trust and use every day”.

He said the integration gives brokers a quantitative view of how a client’s other debts influence the best home loan strategy, along with “a documented rationale that supports their Best Interests Duty obligations”.

 

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