Application Of An Accountant 's Letter Essay

Application Of An Accountant 's Letter Essay

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First things first, we will address your comments regarding the requirement that accountants hold an ACL before they could provide an accountant’s letter or capacity to repay certificate to Bluestone, then with that out of the way, we will comment on what’s the best foot forward for Bluestone regarding using an accountant’s letter to verify an applicant 's financial situation.
CPA Australia’s position
The NCCP Act requires those involved in consumers obtaining credit contracts or consumer leases to have a credit licence (or have an authorisation from a credit licensee) and to comply with responsible lending requirements. Broadly, those who need to be licenced are credit providers or credit assistance providers. A credit provider provides consumer credit directly, ie a lender. A credit assistance provider helps customers to obtain consumer credit but does not provide it directly, eg. brokers.
An accountant, whether a CA or a CPA, usually does not engage in credit activities described above, so an accountant generally does not need a credit licence or be an authorised representative of a credit licensee. Unless the provision of an accountant’s letter or capacity to repay certificate constitute such credit activities, the accountant providing the letter or the certificate should not be required to be licenced or authorised so as to provide the letter or the certificate. While CPA Australia has published guidance notes to assist members when advising on consumer credit (http://www.cpaaustralia.com.au/professional-resources/financial-planning/policy-and-research/the-national-credit-reform-package-and-your-options/signing-client-declarations-for-loans-now-requires-a-credit-licence), and the one titled “Accountant’s Letters & Capacity t...


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...low an accountant’s letter to be used in conjunction with other supporting documents, but not on its own. Bluestone could consider requiring interim statements plus an accountant’s letter (which should meet the “reasonable” test and they are easy for an applicant to obtain), or an accountant’s letter and certified balance sheet and P&L statements. Whether Bluestone would only accept an accountant’s letter from a CPA is a decision for the business. ASIC guidelines do not reference whether an accountant is a CA or a CPA.
We also note here that currently, a major focus of ASIC’s work is responsible lending, and responsible lending is also a hot topic for FOS and CIO. As such whilst Bluestone may want to rely solely on an accountant 's letter to verify an applicant 's financial situation, doing so in the current environment might not be favourably received at this point.

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