Even though the government proposes to postpone the National Credit Act responsible lending provisions to 1 January 2011, ASIC will require lenders to have plans in place as part of the licensing process.

Draft RG104 states:
“RG 104.89 We also expect that you will have measures in place for complying with new requirements as they arise. For example, the responsible lending requirements in Chapter 3 of the National Credit Act will not commence until [date to be advised]; however, we would expect credit licence applicants who apply before this date to have plans to implement adequate supervision once these requirements commence.”