Draft ASIC Regulatory Guide 104 makes it clear that ASIC will require credit licensees to lodge an annual compliance certificate, most likely similar to FS 71 for your AFS Licence.

Now is the time to review your compliance framework: credit compliance should be linked into your overall risk management system and audit and assurance program.

We will be discussing credit compliance under the new system in detail at our new site here and at our seminars in August (information here).