AI for Mortgage and Finance Brokers: What It Can Do Safely

A broking business runs on follow-up: fact finds, document lists, payslips arriving in pieces, lender questions and settlement dates, while new enquiries keep coming in. Much of that is administration, which is where AI helps. The advice itself is regulated, and that line should shape any rollout.

What can AI do in a broking business?

Task	What the AI does	Who stays responsible
New enquiries	Answers or returns the call, captures contact details and loan purpose, books a broker appointment	Broker decides next steps
Document chasing	Sends the agreed checklist, tracks what has arrived, sends polite reminders for what is missing	Broker or processor checks documents
Call notes	Transcribes and drafts a file note of the client conversation	Broker reviews and approves the note
CRM updates	Logs activity, updates stages and creates tasks	Team spot-checks; AI has no delete rights
Status follow-ups	Drafts updates to clients and referral partners from the broker's notes	Broker approves before sending
Product or lender recommendations	Nothing	Broker only

The common thread is that AI moves information and drafts; the broker judges. For the follow-up side in more detail, see our comparison of automated CRM follow-up tools.

What should AI not do for a broker?

Anything that amounts to credit assistance or a lending judgement. Under the best interests duty, mortgage brokers must act in the best interests of the consumer when providing credit assistance (ss 158LA and 158LE of the National Consumer Credit Protection Act 2009, explained in ASIC Regulatory Guide 273). The responsible lending obligations in Chapter 3 of the same Act aim to minimise the risk that consumers enter into, or are encouraged to stay in, an unsuitable credit product, and RG 209 notes they apply to credit assistance providers such as mortgage and finance brokers.

So an AI employee in a broking business should be set up to decline and escalate when a borrower asks things like:

• "Which lender should I go with?" or "Is this rate good?"
• "How much can I borrow?"
• "Should I fix or go variable?" or "Should I refinance?"
• "Will I get approved?"

A safe response acknowledges the question, explains the broker will cover it, and books a call. Test that rule with real phrasing before going live.

How does AI fit with record-keeping under the best interests duty?

This is where AI can genuinely help. RG 273 (RG 273.162 to RG 273.172) says ASIC expects brokers to keep records of how they acted when providing credit assistance, including inquiries into the consumer's circumstances, relevant conversations, the options and recommendation given and why. It notes records do not have to be paper-based and can include file notes, records of conversations, correspondence and audio recordings.

An AI that drafts a structured note after each client call can make those records more complete and consistent. Two cautions: the note must be accurate, so the broker should review it before it is saved to the file; and the AI should record what was said, not add its own assessment of what suits the client.

What does ASIC say about automated systems?

RG 209 says ASIC's guidance is technology neutral and responsible lending obligations can be met online or face to face (RG 209.27). Where licensees use automated decision systems to compile and assess consumer information, ASIC expects (RG 209.254) that:

• the system, rules and algorithms are tested before implementation and at regular intervals;
• it can identify situations needing further inquiries or verification and refer them for manual consideration; and
• it can maintain or produce a meaningful record of the assessment.

An admin-focused AI employee should not be assessing applications at all, but the same principles are a sound standard for any automation that touches a loan file. If you are a credit representative, RG 273 also notes licensees must take reasonable steps to ensure their mortgage brokers comply, so check with your licensee before introducing an AI tool.

How should borrower data and credit information be handled?

Loan files hold some of the most sensitive information a business can collect: identity documents, payslips, bank statements and credit reports. Most businesses with turnover of $3 million or less are exempt from the Privacy Act, but the OAIC notes that Part IIIA, which regulates consumer credit information including credit reports, can apply to some small businesses. Check your obligations with your licensee or adviser.

Practical controls for an AI connected to broking systems:

• never paste borrower information into public AI tools, which the OAIC recommends against;
• let the AI see the document checklist and status, not the contents of every statement, unless the task needs it;
• give it no ability to submit applications or contact lenders on its own;
• keep logs of what it read and sent.

Follow-up texts and emails also need to meet the Spam Act; ACMA's guidance requires consent, sender identification and an unsubscribe option honoured within 5 working days. Our Privacy Act checklist for AI covers the wider privacy steps.

How to introduce AI into a broking business, step by step

1. Map one loan file end to end. List every touchpoint from enquiry to settlement and mark each as admin or advice.
2. Pick one admin workflow first. Document chasing or enquiry intake are usually the clearest wins.
3. Write the escalation rules. Define the questions the AI must hand to a broker, and test them.
4. Set least-privilege access. Connect only the CRM, calendar and document checklist it needs.
5. Run draft-first. Have a broker approve client messages and file notes until the drafts are consistently right.
6. Check with your licensee. Confirm the setup fits their compliance requirements and record-keeping systems.
7. Review weekly. Read the logs, fix errors at the source and expand only when the first workflow is stable.

For security questions such as approvals and logs, see our AI employee security FAQ. If you want help scoping an admin-only AI employee for your broking business, see how Wharq works on our services page.

AI for mortgage brokers: frequently asked questions

Can AI give borrowers loan recommendations?

It should not. Recommending products or lenders is credit assistance, and the best interests duty and responsible lending obligations sit with the broker and licensee. Set the AI to hand those questions to a broker.

Can an AI write file notes for a loan file?

It can draft them from a call transcript, which can make records more complete. ASIC's RG 273 says records can include file notes and records of conversations. The broker should review each note for accuracy before it is saved.

Is it safe to let AI read bank statements and payslips?

Only with a clear need, a controlled platform, least-privilege access and logs. For most document-chasing tasks, the AI only needs to know which documents have arrived, not what is in them. Never use public AI tools for borrower documents.

Do I need my licensee's approval to use AI?

ASIC's RG 273 says licensees must take reasonable steps to make sure their mortgage brokers comply with the best interests obligations. Check with your licensee before connecting an AI tool to client data, as it may have its own requirements.

Can AI follow up borrowers by SMS?

Yes, within the Spam Act for commercial messages: consent, sender identification and a working unsubscribe honoured within 5 working days. Start with drafts the broker approves.

Sources

1. ASIC, "Regulatory Guide 273: Mortgage brokers: Best interests duty" (issued 24 June 2020)
2. ASIC, "Regulatory Guide 209: Credit licensing: Responsible lending conduct" (issued 9 December 2019)
3. OAIC, "Small business" (accessed October 2026)
4. OAIC, "Guidance on privacy and the use of commercially available AI products" (published 21 October 2024, updated 17 January 2025)
5. ACMA, "Avoid sending spam" (accessed October 2026)