The Broker Times · Alt-Doc Placement Brief
The Alt-Doc Shelf Just Got Another Name On It
Firstmac’s 22 October launch, the numbers behind it, and where the file note now has to do its work.
Two headline rates, two different clients
| What was announced | The detail as published | Why it changes the comparison |
|---|---|---|
| Firstmac alt-doc Launched 22 Oct 2026 |
From 6.99%, owner-occupied P&I at 70% LVR. Two years’ trading, strong credit, six months of lodged BAS. Variable or fixed, P&I or interest-only, optional offset. Low application fee, no ongoing monthly fee. Maximum LVR and loan size not stated in the release. | An ongoing product aimed at the premium end of alt-doc, funded through a separate RMBS program. |
| Rate Money Evolve Easy Doc Promotional, per Broker Daily’s 1–8 Oct round-up |
From 6.99% for owner-occupied P&I up to 80% LVR, available until 1 December. No application, risk fee or LMI. Dollar-for-dollar refinancing for self-employed up to 80% LVR and loans up to $2.5m. | Same headline number, ten more points of LVR — but with an expiry date on the offer. |
Where RG 273 actually lands on an alt-doc file
Cost is prioritised
RG 273.51 lists interest rate, fees and charges and repayment size as cost factors brokers should prioritise.
Dearer needs evidence
RG 273.54: a higher-cost recommendation “will need to be supported by evidence” showing why it is in the client’s best interests.
Limited access is recognised
RG 273.60 accepts that lender credit policy, pricing and risk appetite can put the cheapest products out of reach.
But still compare
RG 273.61 says explain why those products are unavailable and the limitations involved — and still consider the cost of the options that are available.
The takeaway
Firstmac’s entry does not make alt-doc placement easier — it makes the second half of the file note harder. The question moving onto your notes is no longer only why the bank said no, but why this alt-doc lender and not the others your client could also have been approved with.
The Broker Times · Loan Tips
Firstmac’s Alt-Doc Loans Start at 6.99% at 70% LVR on Six Months of BAS. The Harder File Note Is Now Which Alt-Doc Lender, Not Whether
A prime non-bank joining the alt-doc shelf does not make self-employed placement easier. It moves the cost comparison inside alt-doc — and RG 273.61 has something specific to say about that.
Firstmac put an alt-doc loan on its shelf on 22 October. Taken on its own, that is one more product sheet to file and a rate to remember. Read it alongside the rest of this month’s lender news and it says something more useful about where self-employed placement has got to: alt-doc has stopped being the place you send a good client when the bank says no, and started being a shelf you have to choose from and justify.
That second part is where the work has moved.
What Firstmac actually launched
Firstmac’s own release, published 22 October 2026, describes an alt-doc loan for established self-employed borrowers, open to both owner-occupiers and investors. Rates start at 6.99% for an owner-occupied principal-and-interest loan at 70% LVR. Borrowers can take variable or fixed, principal and interest or interest-only, with an optional offset account. There is a low application fee and no ongoing monthly fee.
The entry conditions are the part to commit to memory. Firstmac asks for at least two years operating the business, a strong credit profile, and income demonstrated through six months of lodged ATO Business Activity Statements.
Two things the release does not state: the maximum LVR and the minimum or maximum loan size. The 70% figure is attached to the starting rate, not published as a ceiling. Confirm both with Firstmac before you quote a deposit requirement or a loan amount to a client.
Firstmac chief commercial officer Marie Mortimer drew the target narrowly. “We’re targeting established, high-quality self-employed customers,” she said in the release, noting that these borrowers “can find themselves paying substantially-higher interest rates” and that Firstmac is “not looking to compete across the entire alt-doc market” but is aiming at “the premium end, where borrowers have strong credit credentials”. On what it offers brokers, she was plain: “For brokers, it’s about having another competitive option for a good customer.”
Trade coverage adds the funding and strategy picture. MPA reported that the loans are funded through Firstmac’s Eagle RMBS program, separate from the Benchmark program behind its prime book, and that Firstmac manages $23 billion in residential mortgages. Mortimer told MPA the design is deliberately contained — “by keeping it quite narrow and having quite a simple assessment process” — and that “we’ll never say never, but for now we think that there’s a good market with just this segment of it.”
Read that as a placement signal, not marketing. A lender telling you it has narrowed its appetite on purpose is telling you where its approvals will be fast and where they will not come at all. A premium-end alt-doc product with a simple assessment process is built for a specific client: clean file, solid trading history, BAS up to date, deposit or equity at or near 30%. Clients outside that shape belong somewhere else on your panel, and sending them anyway costs you turnaround, not just a decline.
Why the self-employed book keeps drifting to non-banks
The rate backdrop is doing some of this. The RBA’s cash rate target sits at 4.60%, effective 30 September 2026 — the fourth 25 basis point increase of the year, following rises on 4 February to 3.85%, 18 March to 4.10% and 6 May to 4.35%, with no change at the June and August decisions. Australian Broker’s report on the Firstmac launch tied the move to tighter bank serviceability rules pushing more self-employed borrowers toward non-banks.
But serviceability policy is only half of it, and brokers know the other half better than anyone. A PAYG client’s income arrives in exactly the shape a bank’s assessment process was designed around: two payslips, a predictable base, a YTD figure that reconciles. A self-employed client’s income does not. It is seasonal, lumpy, run through an entity, reduced by legitimate depreciation and one-off expenses, and often deliberately structured for tax rather than for a credit assessor. Nothing about that makes the client a worse risk. It makes them a worse fit for a process built on payslips.
What is worth noticing is that the drift is not all one way. The same Broker Daily policy round-up for 1–8 October recorded Bank of Sydney removing the company guarantee requirement for consumer-purpose loans to self-employed borrowers using a corporate entity, and allowing all depreciation in the most recent tax return to be added back for SME servicing, subject to credit assessment. For a client with current financials, a change like that can reopen a full-doc path you had already written off. The lesson is unglamorous: an alt-doc recommendation made on a mental model of lender policy from six months ago is a recommendation made on stale information.
The price gap narrowed, so the comparison moved
MPA reported that lenders it spoke to say the pricing gap between banks and alt-doc has narrowed substantially, and that this is squeezing margins. It also set out the company Firstmac is joining, naming Pepper Money, Bluestone, Resimac, ORDE Financial, Liberty, Thinktank and Brighten as established alt-doc lenders — seven names, with Firstmac making an eighth. On MPA’s reporting, Pepper Money says around a third of its customers use alt-doc options, and alt-doc is a core part of Resimac’s home loan range.
Sit with what that does to your file. When alt-doc was materially dearer than prime and only two or three lenders would look seriously at a BAS, a broker’s decision was close to binary: full-doc if the financials stack up, alt-doc if they do not, and the reasoning wrote itself. With a crowded shelf and a narrower premium, the decision stops being whether and becomes which — and “which” is a comparison, with a cost dimension, between lenders your client could plausibly be approved with.
A concrete illustration from this month. Firstmac’s starting rate is 6.99% for owner-occupied P&I at 70% LVR. Broker Daily’s 1–8 October round-up recorded Rate Money promoting its Evolve Easy Doc product from 6.99% for owner-occupied P&I up to 80% LVR, with no application fee, risk fee or LMI, available until 1 December, plus dollar-for-dollar refinancing for self-employed borrowers up to 80% LVR on loans to $2.5 million.
Same headline number, different client. On those two published sets of terms, 6.99% buys a 30% deposit requirement in one case and a 20% deposit requirement in the other — and one of them is a promotion with a date on it. A client with 22% equity is not choosing between two equal 6.99% loans. They have one option at that rate, for now. A rate alone is not a comparison, and a file note that records only the rate has not recorded the comparison.
Where RG 273 lands on an alt-doc file
The best interests duty sits in Part 3-5A of the National Consumer Credit Protection Act 2009, and ASIC’s guidance on it is Regulatory Guide 273, Mortgage brokers: Best interests duty, issued June 2020. Four paragraphs in that guide do most of the work on an alt-doc file, and they are worth reading rather than paraphrasing from memory.
RG 273.51 says ASIC generally expects the cost of a credit product — “such as interest rate, fees and charges and the size of repayments” — to be a factor brokers should prioritise. RG 273.54 goes further: a failure to consider cost and investigate the lowest cost options available “may suggest non-compliance”, and “any situation where a higher cost loan is recommended will need to be supported by evidence demonstrating why that recommendation is in the consumer’s best interests”. RG 273.56 adds the obvious counterweight, that the lowest interest rate is not necessarily the lowest cost option once offsets, redraw and annual or establishment fees are counted.
Then come the two paragraphs that matter most for self-employed work. RG 273.59 acknowledges that access to certain products may be limited by a consumer’s circumstances, including credit risk and desired loan amount. RG 273.60 states that “the credit policy, pricing practices and risk appetite of the credit provider may preclude some consumers from accessing the lowest cost products”. And RG 273.61 says that in those situations a broker should do two things: explain why the cheaper products are not available and the limitations involved with the available options, and “still consider the cost of the available options” where the application is reasonably likely to be approved.
That second limb is the one the crowded shelf activates. RG 273.60 has always given brokers the answer to “why not the cheapest loan on the market” for a client whose BAS-based income puts bank pricing out of reach. RG 273.61(b) asks the next question, and until recently it was nearly rhetorical. With eight names on the alt-doc shelf and a narrower premium, the cost of the available options is a real comparison with a real answer — and the available options are the ones your client could actually be approved with, not the whole market.
This is general information about published guidance, not advice on your obligations. RG 273 runs to considerably more than these paragraphs, and how any of it applies to a given file turns on that file. Your licensee or aggregator compliance team is the right place to settle how your process should evidence a recommendation, and anything that reads as a genuine grey area is worth independent legal advice rather than a judgement call between appointments.
The document set is the real gate
Brokers tend to triage alt-doc clients on rate and LVR. The faster filter is usually the paperwork, because that is what cannot be negotiated late in the process.
Firstmac’s stated requirements — two years trading, strong credit, six months of lodged BAS — rule in and out quite a lot before anyone looks at a rate. Three common clients fall outside them:
- The client 14 months into an ABN. Trading history is a hard gate, not a soft preference. They need a lender whose published minimum they actually meet, or a different structure.
- The client whose BAS lodgements are behind. Six months of lodged BAS is a sequencing problem, not a credit problem. The first call is to their accountant, not to a lender, and getting that order right can save a fortnight.
- The client with a recent default or a strained credit file. A product explicitly aimed at the premium end is not where a near-prime file gets its best outcome, however good the rate looks on the sheet.
The practical habit worth building: confirm the document set and the trading-history minimum before you shortlist on price. It reorders the conversation with the client from “here is a rate” to “here is what we need in place, and here is what that opens up” — which is both a better client experience and a cleaner file.
The demand problem no product sheet fixes
There is a larger issue sitting behind all of this, and no lender launch solves it. Research from Bluestone, reported by Australian Broker on 22 September, surveyed more than 18,000 Australians and found that self-employed borrowers are actively seeking professional advice — just not from brokers. On that reporting, 62% of self-employed borrowers had paid for some kind of professional adviser in the previous 12 months, but only 10% of those surveyed had gone to a mortgage broker for assistance. Facing a complex financial situation, 36% said they would prefer to speak with a bank against 25% who would turn to a broker, and two-thirds said they would go directly to a bank or lender rather than a broker.
The awareness numbers in that research are the ones to dwell on: around 45% were unfamiliar with non-bank lenders, while 63% said they would consider one if it were presented to them. Separately, 68% were concerned lending conditions would tighten over the next year. These are a lender’s own survey figures as reported by one outlet rather than independently verified market data, so weigh them accordingly — but the direction is hard to argue with.
“But our research suggests many self-employed borrowers aren’t making it in front of the broker in the first place.” Tony MacRae, chief commercial officer, Bluestone, quoted in Australian Broker, 22 September 2026
Bluestone’s head of sales strategy and performance, Aaron Taylor, put the gap down to visibility: “One of the challenges is awareness; awareness of non-bank lenders remains relatively low.” The same reporting noted that three in four brokers had turned away at least one non-prime borrower in the previous 12 months — not all of them self-employed, but a useful measure of how much enquiry currently leaves the channel without an outcome.
Put the two halves together and the commercial reading is straightforward. The shelf of lenders willing to write a well-documented self-employed loan at a competitive rate is getting longer. The number of self-employed Australians who know that, and who think of a broker as the person to ask, is not keeping pace. That is a marketing and referral problem with a known answer: accountants and bookkeepers, who are already in front of these clients and already handling the BAS that the loan now turns on.
What to review this week
A six-point self-employed placement review
- Refresh your alt-doc shortlist to current terms. Rates, maximum LVRs, trading-history minimums and accepted document sets, pulled this month rather than remembered. Note which offers have expiry dates on them.
- Separate the promotions from the products. A promotional rate with a December expiry and an ongoing product are different recommendations for a client settling in February. Record which one you relied on and when it was current.
- Re-test your full-doc assumptions. Servicing add-backs and guarantee requirements have moved on some lenders. A client you placed on alt-doc last quarter may now qualify full-doc with current financials.
- Gate on documents before price. Confirm lodged BAS, trading history and credit position before you shortlist. Where BAS lodgements are behind, the accountant call comes first.
- Read your own alt-doc file notes against RG 273.61. Do they explain why cheaper products were unavailable and what the chosen option’s limitations are — and do they show that the cost of the realistically available options was considered, not just the one recommended? Take anything unclear to your licensee’s compliance team rather than deciding alone.
- Pick up the phone to two accountants. They are holding the BAS, they are already the trusted adviser, and on the research above most of their self-employed clients would go straight to a bank without them.
What to watch next
Three things worth tracking. First, whether the premium end of alt-doc keeps compressing — if the gap to prime narrows further, the cost comparison inside alt-doc becomes a more regular feature of your files, not an occasional one. Second, whether maximum LVRs and loan-size caps get published as the newer entrants settle in, since those are the figures that decide placement in practice. Third, whether full-doc servicing policy keeps loosening at the mutual and second-tier end, which would pull some of this volume back out of alt-doc altogether.
Mortimer told MPA that Firstmac is reviewing strategy in light of a slower market and recent government changes, including around investment lending and self-managed super fund borrowing. Appetite that was set in October may not be the appetite you are working with in March.
Key takeaways
- Firstmac launched an alt-doc loan on 22 October from 6.99% for owner-occupied P&I at 70% LVR, requiring two years’ trading, a strong credit profile and six months of lodged ATO BAS. Maximum LVR and loan size were not stated in the release — confirm both before quoting.
- MPA names seven established alt-doc lenders Firstmac is joining and reports that the pricing gap between banks and alt-doc has narrowed substantially.
- A crowded shelf shifts the harder part of the file note from why not a bank to why this alt-doc lender. RG 273.61 says brokers should explain why cheaper products are unavailable and still consider the cost of the options that are available.
- Two lenders advertised 6.99% this month at different LVR limits and with different shelf lives, which is why a recorded rate is not a recorded comparison.
- Research from Bluestone reported by Australian Broker found only 10% of those surveyed went to a mortgage broker, and two-thirds of self-employed borrowers would go direct to a bank or lender — the growth constraint is reach, not product.
Frequently asked
Does recommending a dearer alt-doc loan breach the best interests duty?
ASIC’s guidance does not say a higher-cost loan cannot be recommended. RG 273.54 says a higher-cost recommendation “will need to be supported by evidence demonstrating why that recommendation is in the consumer’s best interests”, and RG 273.60 recognises that lender credit policy, pricing and risk appetite can put the cheapest products out of reach. The exposure is an unevidenced recommendation, not a dearer one. How that applies to your files is a question for your licensee or aggregator compliance team.
What does “six months of lodged BAS” rule out in practice?
Clients whose BAS lodgements are behind, which is a sequencing issue rather than a credit one. The first call is usually to the client’s accountant. Establishing that early avoids shortlisting on a rate the client cannot yet access.
If two lenders both advertise 6.99%, does it matter which I use?
On this month’s published terms, yes. Firstmac’s starting rate attaches to a 70% LVR owner-occupied P&I loan; Broker Daily recorded Rate Money’s Evolve Easy Doc promotion from the same rate up to 80% LVR but available only until 1 December. Deposit requirement, fee structure and how long the offer lasts all differ, and a client with 22% equity is not choosing between equals.
Is alt-doc still the default for a self-employed client?
Not automatically. Servicing policy for self-employed borrowers has moved at some lenders — Broker Daily’s early-October round-up recorded Bank of Sydney allowing all depreciation in the most recent tax return to be added back for SME servicing, subject to credit assessment, and removing a company guarantee requirement for consumer-purpose loans to self-employed borrowers using a corporate entity. A client with current financials is worth re-testing full-doc before defaulting to alt-doc.
Sources consulted
- Firstmac, “Firstmac launches alt-doc loans for established self-employed borrowers”, 22 October 2026 (firstmac.com.au news room)
- MPA, “Firstmac’s alt-doc debut takes on Pepper Money and rivals”
- Australian Broker, “Firstmac alt-doc loans target premium self-employed borrowers”
- Australian Broker, “Self-employed borrowers are major untapped market, says Bluestone”, 22 September 2026
- Broker Daily, “Broker policy round-up: Lender changes at a glance 1–8 October”
- ASIC Regulatory Guide 273, Mortgage brokers: Best interests duty, June 2020
- Reserve Bank of Australia, cash rate target statistics (rba.gov.au)
Breaking news for modern brokers
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Self-Employed Placement Triage
Four questions on the client in front of you. It returns the order to work in and what the file note still has to show — not a recommendation.
Disclaimer: This article is for general information and professional development purposes only. It does not constitute legal, compliance, or financial advice. Brokers should consult their aggregator’s compliance team and, where required, seek independent legal advice regarding their obligations under the National Consumer Credit Protection Act 2009 and ASIC’s responsible lending guidelines.

