Overview
This guide covers FrankieOne’s KYC solution for lenders and credit providers, designed to support identity verification, fraud prevention, and responsible lending obligations under the National Consumer Credit Protection Act.Summary
Available Workflows
| Workflow | Purpose | When to Use |
|---|---|---|
AUS-Basic3V-TwoPlusID | Standard verification | Personal loans, standard consumer credit |
AUS-Advanced3V-TwoPlusID | Enhanced verification | Home loans, high-value loans, elevated risk |
AUS-Risk-CDD-Lending | Fraud detection | Lending-specific fraud signals |
AUS-Business-KYB | Business verification | Small business loans, director verification |
Verification by Loan Type
| Loan Type | Value Range | Recommended Workflow |
|---|---|---|
| Personal loan | Under $10K | AUS-Basic2V + fraud scoring |
| Personal loan | $10K+ | AUS-Basic3V-TwoPlusID |
| Vehicle loan | 100K | AUS-Basic3V-TwoPlusID + document |
| Home loan | $200K+ | AUS-Advanced3V-TwoPlusID + biometric |
| Business loan | Variable | Individual + AUS-Business-KYB |
Risk-Based Verification Flow
Decision Outcomes
| Outcome | Action |
|---|---|
| Verified - Low Risk | Proceed to credit assessment |
| Verified - Medium Risk | Proceed with caution flags |
| Step-Up Required | Request additional verification |
| High Risk | Manual review or decline |
Key Fraud Signals
| Signal | Risk Level | Description |
|---|---|---|
| Synthetic identity indicators | Critical | Fabricated identity patterns |
| Application velocity | High | Multiple applications across lenders |
| Credit file inconsistencies | High | Mismatch with credit bureau data |
| Device on fraud network | Critical | Known fraudulent device |
Support
- Documentation: docs.frankieone.com
- Support: Contact your FrankieOne representative
Expanded Details
Regulatory Context
Disclaimer: The information in this section is provided for general guidance only and does not constitute legal or compliance advice. Customers must seek independent legal and regulatory advice to ensure their implementation meets their specific regulatory obligations. FrankieOne is not responsible for customers’ compliance decisions or outcomes.
Regulatory Updates: Lending regulations continue to evolve. Customers should monitor updates from ASIC regarding responsible lending, hardship obligations, and consumer protection requirements.
Australian Lending Regulatory Framework
Lenders providing consumer credit must comply with multiple regulatory requirements. FrankieOne’s lending workflows can support these obligations:| Obligation | Regulatory Source | How FrankieOne Can Support |
|---|---|---|
| Customer Identification | AML/CTF Act (where applicable) | Automated identity verification workflows |
| Identity Fraud Prevention | General law, responsible lending | Fraud detection and synthetic identity prevention |
| Responsible Lending | NCCP Act | Identity verification to support credit assessment |
| Hardship Identification | NCCP Act | Customer verification for hardship applications |
| Privacy | Privacy Act | Secure handling of personal information |
| Record Keeping | Various | Audit trails and verification records |
National Consumer Credit Protection Act (NCCP)
The NCCP Act establishes responsible lending obligations. While FrankieOne provides identity verification (not credit assessment), verification supports:| NCCP Requirement | How Identity Verification Supports |
|---|---|
| Make reasonable inquiries | Verified identity ensures inquiries relate to correct person |
| Verify information | Identity verification as foundation for information verification |
| Assess suitability | Confirmed identity enables accurate credit assessment |
| Not unsuitable credit | Fraud detection helps prevent unsuitable lending to synthetic identities |
Note: Credit assessment, income verification, and suitability determination are separate from identity verification.
AML/CTF Obligations
Some lenders are AUSTRAC reporting entities with AML/CTF obligations:| Entity Type | AML/CTF Status |
|---|---|
| ADI lenders (banks) | Reporting entity |
| Finance companies (some) | May be reporting entity |
| Mortgage brokers | Not typically reporting entity |
| Peer-to-peer lenders | Depends on structure |
Workflow Configuration Details
Standard Verification: AUS-Basic3V-TwoPlusID
Suitable for personal loans and standard consumer credit.
Core Checks:
| Check Type | Purpose |
|---|---|
| Government ID verification (DVS) | Primary identity confirmation |
| Credit bureau identity check | Cross-reference and credit file link |
| Electoral roll | Address verification |
| PEP and sanctions screening | AML risk assessment (where applicable) |
Enhanced Verification: AUS-Advanced3V-TwoPlusID
For higher-value loans, home loans, and elevated risk scenarios.
Additional Checks:
| Check Type | Purpose |
|---|---|
| Biometric verification | Face-to-document matching |
| Document authenticity | Fraud and tampering detection |
| Enhanced address verification | Multiple source address confirmation |
| Adverse media screening | Additional risk assessment |
Fraud Detection: AUS-Risk-CDD-Lending
Lending-specific fraud detection workflow.
Risk Signals:
| Signal | Risk Level | Description |
|---|---|---|
| Synthetic identity indicators | Critical | Fabricated identity patterns |
| Application velocity | High | Multiple applications across lenders |
| Credit file inconsistencies | High | Mismatch with credit bureau data |
| Device on fraud network | Critical | Known fraudulent device |
| Email/phone risk | Medium-High | Recently created or disposable |
| Address risk | Medium | Non-residential or high-risk address |
Step-by-Step Implementation
Note: This section describes the conceptual implementation flow. For actual API endpoints and schemas, refer to the FrankieOne API Documentation.
Implementation Flow
Step 1: Collect Applicant Details
Collect required information for identity verification:- Full legal name
- Date of birth
- Residential address (current and previous if under 3 years)
- Email address
- Mobile phone number
- Government ID details
- Employment details (for credit assessment)
Step 2: Identity Verification
Verify applicant identity against authoritative sources. Verification by Loan Type:| Loan Type | Minimum Verification |
|---|---|
| Personal loan under $10K | 2-source electronic |
| Personal loan $10K+ | 3-source electronic |
| Vehicle loan | 3-source + document recommended |
| Home loan | Enhanced + document + biometric |
Step 3: Fraud Assessment
Evaluate fraud signals specific to lending. Lending Fraud Patterns:| Pattern | Detection Approach |
|---|---|
| Synthetic identity | Cross-source consistency, credit file age |
| Identity takeover | Device signals, application behaviour |
| First-party fraud | Historical data, bureau alerts |
| Application fraud | Velocity checks, data consistency |
| Income fraud | Outside FrankieOne scope (income verification) |
Step 4: Risk Decision
Combine identity and fraud signals for risk decision.Step 5: Support Credit Assessment
Verified identity enables accurate credit assessment by ensuring:- Credit file belongs to applicant
- Previous applications linked correctly
- Fraud indicators flagged before credit decision
Note: Credit assessment, income verification, and affordability checks are outside FrankieOne’s identity verification scope.
Risk Tier Examples
Tier 1: Low Risk - Standard Verification
Application Profile:- Personal loan $8,000
- Australian citizen, employed
- Strong credit bureau match
- No fraud signals
Sarah Testone, 34, applies for an $8,000 personal loan for home renovations. Identity verified against DVS (driver licence) and credit bureau. Name, DOB, and address all match. No fraud signals detected. Identity verification complete, proceeds to credit assessment.
Tier 2: Medium Risk - Enhanced Verification
Application Profile:- Vehicle loan $45,000
- Recent address change
- New to credit bureau
- Moderate fraud signals
Michael Testtwo, 23, applies for a $45,000 car loan. Identity verified but credit bureau shows thin file (recently turned 18 when file created). Address changed 2 months ago. Device shows no prior applications. Step-up triggered: driver licence document uploaded and verified. Proceeds to credit assessment with flags for thin file.
Tier 3: High Risk - Manual Review
Application Profile:- Home loan $650,000
- Identity inconsistencies
- Application velocity detected
- High-risk fraud indicators
Application received for $650,000 home loan. Name matches but DOB discrepancy between application and credit file. Credit bureau shows 4 recent inquiries from other lenders in 30 days. Device fingerprint associated with previous declined application at another lender. Escalated to fraud team for investigation before proceeding.
Edge Cases and Special Handling
Joint Applications
Many loans involve joint applicants (e.g., home loans with partners).| Scenario | Verification Requirement |
|---|---|
| Married couple | Both applicants verified independently |
| De facto partners | Both applicants verified independently |
| Parent guarantor | Guarantor verified + legal capacity |
| Business partners | All parties verified + business verification |
Guarantor Verification
| Requirement | Verification |
|---|---|
| Identity verification | Standard verification process |
| Legal capacity | Age 18+, not under administration |
| Independent legal advice | Document confirmation (outside FrankieOne) |
| Relationship to borrower | Disclosed and documented |
Refinance Applications
| Consideration | Approach |
|---|---|
| Existing customer | Leverage existing verification if recent |
| Verification currency | Re-verify if over 12 months |
| Address changes | Verify current address |
| Name changes | Verify with supporting documents |
Small Business Lending
| Component | Verification |
|---|---|
| Individual borrower | Standard individual verification |
| Business entity | Business verification (ABN, ASIC) |
| Directors/partners | Individual verification of all |
| Guarantors | Individual verification + capacity |
Fraud Prevention
Lending-Specific Fraud Vectors
| Fraud Type | Description | Mitigation |
|---|---|---|
| Synthetic Identity | Fabricated identity using mixed real/fake data | Cross-source consistency, credit file analysis |
| Identity Takeover | Using stolen identity to obtain credit | Device intelligence, behavioural signals |
| First-Party Fraud | Borrower provides false information | Data verification, velocity checks |
| Application Fraud | False application details | Automated verification, document checks |
| Broker Fraud | Falsified applications via broker channel | Broker verification, application analysis |
Synthetic Identity Detection
| Indicator | Detection |
|---|---|
| Credit file age vs applicant age | File created recently for older applicant |
| Authorised user patterns | Only authorised user accounts, no primary |
| Address inconsistencies | Multiple identities at same address |
| SSN/TFN anomalies | Number patterns inconsistent with issue date |
| Data element mismatches | DOB/name combinations don’t match across sources |
Velocity Controls
| Control | Typical Threshold | Action |
|---|---|---|
| Applications per identity per month | 3 | Flag / review |
| Applications per device per week | 2 | Flag / review |
| Applications per address per month | 3 | Flag / review |
| Cross-lender velocity (via bureau) | 5 inquiries/90 days | Enhanced scrutiny |
Integration with Credit Assessment
Identity Verification vs Credit Assessment
| Component | FrankieOne Scope | Credit Assessment (Separate) |
|---|---|---|
| Identity confirmation | ✓ | |
| Fraud detection | ✓ | |
| PEP/sanctions screening | ✓ | |
| Credit score | ✓ | |
| Income verification | ✓ | |
| Expense analysis | ✓ | |
| Serviceability calculation | ✓ | |
| Loan suitability | ✓ |
Data Handoff
FrankieOne provides verified identity data to support credit assessment:- Verified full legal name
- Verified date of birth
- Verified address
- Credit bureau file reference
- Identity verification confidence score
- Fraud risk indicators
Compliance Reporting
Audit Trail Requirements
| Data Category | Retention Period | Purpose |
|---|---|---|
| Identity verification results | Per regulatory requirement | Compliance evidence |
| Document images | Per regulatory requirement | Evidence retention |
| Fraud assessment results | Per regulatory requirement | Fraud investigation |
| Decision outcomes | Per regulatory requirement | Audit trail |
Hardship Verification Support
For customers requesting hardship variations:- Verify identity of person making request
- Confirm they are the account holder
- Support secure communication
Troubleshooting
| Issue | Likely Cause | Resolution |
|---|---|---|
| Credit bureau no-match | Name/DOB format | Verify data entry, check variations |
| Thin credit file flags | Young or new-to-credit applicant | Document verification, alternative data |
| High fraud score | Legitimate signals | Manual review, step-up verification |
| Address mismatch | Recent move | Document proof of address |