The Settlement Date That Wasn't
Priya is a trainee at a small mortgage broking firm. On Friday 14 March she receives a client file for the Nguyen refinance. The client's fixed rate expires on 30 April. Priya's supervisor, Daniel, is on leave until 24 March and has left a note: "Lodge with the lender as soon as the file is complete - we're chasing the 30 April deadline." Reviewing the file, Priya finds the client's most recent payslip is dated 2 February, the lender's policy requires payslips no older than 60 days at lodgement, and the client's ID document is a driver licence that expired on 1 March. The client is travelling and cannot supply new documents until 31 March. Priya also notices Daniel has already entered the application into the lender's portal as "ready to submit", with an electronic signature block pre-filled from the earlier draft. The firm's procedure says any lodgement outside policy must be escalated to the principal broker before submission.
1. Identify the compliance and quality risks in this file and explain why simply submitting as Daniel instructed would be the wrong judgement call.
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The core risks are: (1) Age of evidence - the 2 February payslip will be more than 60 days old by any lodgement after early April, and is already close to the limit; submitting now would breach the lender's policy and could constitute misleading conduct if the file implies the evidence is current. (2) Expired identification - an expired licence fails the lender's ID requirements and, depending on the firm's obligations, may not satisfy verification-of-identity standards. (3) Pre-filled signature block - using an electronic signature captured from an earlier draft without fresh client authorisation risks submitting an application the client has not actually signed in its current form. That is a serious integrity issue, not a clerical shortcut. (4) Procedure breach - the firm's own escalation rule is triggered, and Daniel's instruction cannot override it while he is absent.
Submitting anyway is wrong because it trades a deadline for a compliance failure. The deadline pressure is real but the consequence of a rejected or flagged application - and of an unauthorised signature - is worse for the client and the firm. The correct judgement is to escalate to the principal broker, document the gaps, and contact the client to arrange documents as early as possible after 31 March, while assessing whether the lender will accept an extension request before 30 April.
2. Draft the escalation note Priya should send to the principal broker, and explain what she should and should not do about the pre-filled signature block.
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A sound escalation note is factual, brief and flags each issue with evidence:
Subject: Nguyen refinance - file incomplete, lodgement held The file is in the portal marked ready to submit but I have not submitted it. Three issues: (a) latest payslip dated 2 Feb, lender requires within 60 days at lodgement; (b) client's driver licence expired 1 March, replacement not available until 31 March as client is overseas; (c) the electronic signature block was pre-filled from an earlier draft and I cannot confirm the client authorised the current version. Daniel's note asked for lodgement ASAP but our procedure requires escalation where lodgement is outside policy. Please advise whether we seek a deadline extension from the lender or wait for documents after 31 March.
On the signature block: Priya should not submit it, and should not alter or re-use it herself. She should leave it untouched so the principal broker can see exactly what state the file is in, and flag it explicitly as unauthorised. Re-using a signature the client has not given for this version of the application is the kind of conduct that can amount to submitting a false document. The safe path is to obtain fresh client authorisation once the client is contactable, and to record in the file why the earlier block was not used.