Loan comparison sites

[neddy]

I know this has been discussed on here in the past, but this subject is probably worth revisiting given that ASIC seems to be getting stricter by the year.

So here are two questions:

1. If you purchase a domain name and develop it to list and compare credit card and loan products, do you need to have some sort of licence from ASIC?
   
   
   [*]If you do need a licence, but operate without one, can you get pinged?

I'm hoping Shane, Link and Erhan will comment given that they have tons of experience in this area.

(This is not for me, but for a mate. I stay out of that space. I'm sure it's relevant for others as well though).

Many thanks in advance.

Cheers, Ned

 

[Shane]

To the first question I would say yes.

There is nothing that specifically mentions comparison websites in RG203, however it does talk about intermediaries.

If a website is promoting a credit product and allows a visitor to apply for that product (via an affiliate link for example) then I'd say that they are an intermediary and therefore require a licence.

To the second question I would definitely say yes, but from my experience ASIC will give you a warning first provided that you aren't doing anything too crazy like providing personal advice without a licence or making out as if you do have a licence when you don't.

In saying all that, it's not too difficult to get an ACL if you want to go down that path.

 

[DavidL]

Regardless of ASIC, you may struggle to get affiliate deals if that's the way you plan t5o monetise the site.

I believe some merchants for companies like DGM inisist that their publishers have an ACL

 

[jam]

DGM, Commission Monster and Digital Lead Network have all requested an ACL from me in the past when promoting credit card offers.