Lending - Customer Onboarding

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	$10K -$ 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

Example Scenario:

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

Example Scenario:

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

Example Scenario:

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

​Overview

​Summary

​Available Workflows

​Verification by Loan Type

​Risk-Based Verification Flow

​Decision Outcomes

​Key Fraud Signals

​Support

​Expanded Details

​Regulatory Context

​Australian Lending Regulatory Framework

​National Consumer Credit Protection Act (NCCP)

​AML/CTF Obligations

​Workflow Configuration Details

​Standard Verification: AUS-Basic3V-TwoPlusID

​Enhanced Verification: AUS-Advanced3V-TwoPlusID

​Fraud Detection: AUS-Risk-CDD-Lending

​Step-by-Step Implementation

​Implementation Flow

​Step 1: Collect Applicant Details

​Step 2: Identity Verification

​Step 3: Fraud Assessment

​Step 4: Risk Decision

​Step 5: Support Credit Assessment

​Risk Tier Examples

​Tier 1: Low Risk - Standard Verification

​Tier 2: Medium Risk - Enhanced Verification

​Tier 3: High Risk - Manual Review

​Edge Cases and Special Handling

​Joint Applications

​Guarantor Verification

​Refinance Applications

​Small Business Lending

​Fraud Prevention

​Lending-Specific Fraud Vectors

​Synthetic Identity Detection

​Velocity Controls

​Integration with Credit Assessment

​Identity Verification vs Credit Assessment

​Data Handoff

​Compliance Reporting

​Audit Trail Requirements

​Hardship Verification Support

​Troubleshooting

Overview

Summary

Available Workflows

Verification by Loan Type

Risk-Based Verification Flow

Decision Outcomes

Key Fraud Signals

Support

Expanded Details

Regulatory Context

Australian Lending Regulatory Framework

National Consumer Credit Protection Act (NCCP)

AML/CTF Obligations

Workflow Configuration Details

Standard Verification: `AUS-Basic3V-TwoPlusID`

Enhanced Verification: `AUS-Advanced3V-TwoPlusID`

Fraud Detection: `AUS-Risk-CDD-Lending`

Step-by-Step Implementation

Implementation Flow

Step 1: Collect Applicant Details

Step 2: Identity Verification

Step 3: Fraud Assessment

Step 4: Risk Decision

Step 5: Support Credit Assessment

Risk Tier Examples

Tier 1: Low Risk - Standard Verification

Tier 2: Medium Risk - Enhanced Verification

Tier 3: High Risk - Manual Review

Edge Cases and Special Handling

Joint Applications

Guarantor Verification

Refinance Applications

Small Business Lending

Fraud Prevention

Lending-Specific Fraud Vectors

Synthetic Identity Detection

Velocity Controls

Integration with Credit Assessment

Identity Verification vs Credit Assessment

Data Handoff

Compliance Reporting

Audit Trail Requirements

Hardship Verification Support

Troubleshooting