Trimmed Mean Hit 3.6% in September Against the RBA’s Own 3.3% Forecast for December. RG 273.121 Is the Paragraph for Files Still in Your Pipeline on 3 November

What the ABS actually published

The release is a monthly one, and the ABS reports it in three forms. Over the twelve months to September 2026, the all groups CPI rose 4.3%, up from 4.0% over the twelve months to August and 3.5% over the twelve months to July. In the month of September alone, the CPI rose 0.8% in original terms and 0.6% in seasonally adjusted terms. Annual trimmed mean inflation — the measure that strips the largest price rises and falls from each end of the distribution — was 3.6%, up from a figure for August that the ABS revised down from 3.6% to 3.5% after a change in seasonal factors.

Underneath those totals, the composition is where the broker-relevant detail sits. Housing was the largest contributor to annual inflation, up 5.2%, although that is down from 5.7% in August. Rachael McCririck, the ABS Head of Price Statistics, said housing was the largest contributor, rising by 5.2 per cent. Within housing, new dwelling prices rose 4.7% over the year, easing from 5.4% in August, and rents rose 3.6%. Electricity rose 12.8%, which the ABS attributes mainly to the end of Commonwealth electricity rebates. Transport was up 8.7% over the year, driven by automotive fuel. Food and non-alcoholic beverages rose 3.2%, up from 3.0% in August.

Why 3.6% matters more than 4.3%

Your clients will see 4.3%. The Board will spend more of its time on 3.6%, and the reason is the gap between them. Headline inflation includes the volatile items. The ABS said automotive fuel was excluded from the trimmed mean and that this largely explains the gap between the two measures, and it attributed the monthly rise in fuel prices to higher world oil prices. The electricity figure, which the ABS puts down mainly to the end of Commonwealth rebates, is a change in government policy showing up in a price index rather than a change in underlying energy demand. When the two measures separate by seven tenths of a percentage point, a fair reading is that part of the headline number reflects a global oil price and an unwinding subsidy, not domestic price pressure the Reserve Bank can do much about.

That said, the trimmed mean is not comfortable reading either, and this is the part worth carrying into client conversations. In its August 2026 Statement on Monetary Policy, the RBA forecast trimmed mean inflation of 3.3% by December 2026 and 3.0% by June 2027, with headline inflation at 3.6% by December 2026. September’s 3.6% trimmed mean is already above the December forecast, with two monthly prints still to come before that reference period closes. The same Statement said trimmed mean inflation was expected to remain above 3 per cent until mid-2027 before easing to 2.5 per cent by early 2028, and judged that the risks around its forecasts were, on balance, “skewed to the upside”. September is the kind of print that makes a forecast revision look likely rather than possible.

Context for where the cash rate already is: the RBA’s own cash rate series shows the target at 4.60%, effective 30 September 2026, following a 0.25 percentage point increase. That was the fourth increase of 2026, after moves effective 4 February to 3.85%, 18 March to 4.10% and 6 May to 4.35%, with no change at the June and August meetings. Australian Broker reported today that 4.60% is the highest cash rate since 2011.

What the banks did with the print

CommBank moved on the day. Having previously expected no change in November, its economists now forecast a 0.25 percentage point rise to 4.85% at the November meeting, which would be the fifth rise of 2026. Belinda Allen, CommBank’s Head of Australian Economics, said inflation “overall remains too high” and that “we see the hike in November as an insurance hike to protect against these forces”. CommBank expects holds in December and February, with cuts pencilled in for August and November 2027, though Allen notes “a large degree of uncertainty remains on timing”.

On market pricing, the ABC reported that before the release markets had priced the chance of a November hike at above 60 per cent, without naming the source of that pricing. Treat that figure as one outlet’s reporting rather than an established number, and treat the post-release pricing as unsettled until the week’s trading closes.

The broker-channel read is less about the macro and more about the phone. Alex Ritchie, director and mortgage broker at Sydney-based Strategic Asset and Equipment Finance, told Australian Broker that “another interest rate rise is just another hit to the stomach” for clients, describing the Reserve Bank’s position as “a tricky, tricky balancing act”. He expects another rise before year-end, in December if not November.

The arithmetic that reaches your assessment rate

Here is where a macro story becomes a file problem. APRA’s letter to ADIs of 6 October 2021, signed by then-Chair Wayne Byres, states that all ADIs “should be operating with a buffer of at least 3.0 percentage points over the loan interest rate”. APRA confirmed in its December 2023 macroprudential update that the buffer would be kept at 3 percentage points to maintain prudent lending standards, with Chair John Lonsdale noting that “APRA’s macroprudential settings are dynamic and can be adjusted to address emerging risks when they arise”. Confirm the current setting and your own lenders’ floors with your licensee before you rely on a number in front of a client.

The point for brokers is that the buffer is additive and expressed as a minimum. It is not a ceiling and it does not absorb rate movements. If a lender passes on 25 basis points to a variable product rate, the assessment rate for that product rises by the same 25 basis points, because the buffer sits on top of whatever the product rate is. Capacity moves with it. The exception is a file already being assessed at a lender’s floor rate rather than product-rate-plus-buffer, where a small product move may not change the assessment at all. Knowing which of your lenders is assessing on a floor and which on product-plus-buffer is the difference between a file that survives 3 November untouched and one that does not.

Two second-order effects are worth flagging. First, the living expenses side. Electricity up 12.8% and transport up 8.7% over the year are real movements in the household expense categories that feed benchmark figures, and lenders refresh those benchmarks on their own schedules rather than in lockstep with the CPI. A capacity number quoted in September may be sitting on an older benchmark than the one a lender applies on lodgement. Second, the fixed rate conversation. Fixed rate repricing does not always wait for a Board decision, so a fixed-versus-variable comparison a client saw a fortnight ago may no longer describe your panel. Pull current pricing before you have the conversation again rather than working from the quote on the file.

RG 273.121 and the file that has been sitting

Most brokers know the headline of the best interests duty. Fewer have read the paragraphs about what happens when a file stalls. ASIC’s Regulatory Guide 273, published June 2020, deals with it directly.

RG 273.116 sets the frame: “The best interests duty applies any time you provide credit assistance to the consumer, based on the information available at the time. This information includes reasonably foreseeable changes to the consumer’s personal circumstances and financial situation.”

Then RG 273.121: “When the credit assistance process is subject to delay, you should consider whether you need to start a new assessment or make further inquiries into the consumer’s circumstances before making a recommendation or assisting the consumer to take out a product.”

RG 273.122 sets out what to weigh in making that call: “(a) the length of the delay; (b) whether the information considered is reasonably current and likely to still reflect the consumer’s circumstances; and (c) your responsible lending obligations.” A note to that paragraph adds that responsible lending obligations require inquiries to be undertaken within 90 days of credit assistance being provided, pointing to RG 209.

Read together, those paragraphs are a general-information guide, not a rule that a rate decision triggers a fresh assessment. The language is “you should consider”, and the factors are about currency of information and the length of the delay, not about the cash rate. But a client who received a recommendation in August, went quiet, and now wants to proceed in the second week of November has sat through a delay in a window where product rates, assessment rates and expense benchmarks have all been moving. That is squarely the situation RG 273.122(b) is describing. Whether the information is still reasonably current is a question you have to answer on that file, and RG 273.162 says ASIC expects you to keep records of how you have acted when providing credit assistance, including your inquiries and your consideration, investigation and assessment of the products you recommend. If you conclude the earlier information is still current, the file should say why.

What the duty does not ask of you

This is the part that gets lost when rates move, and it matters for brokers who are about to lose a weekend to re-running pipelines that do not need it. The commentary to Example 8 in RG 273 deals with a broker who recommended a fixed rate loan to a client worried about rising rates, after which rates fell and the client would have been better off on variable. ASIC’s commentary says the broker complied with the duty, because at the time credit assistance was provided the fixed loan was the best option available. It goes on: “Generally, changes that occur after the recommendation is made are not relevant to whether the best interests duty has been complied with.” The guide describes the assessment as a point-in-time one, while still expecting brokers to consider reasonably foreseeable changes.

RG 273.118 makes the same point from the other direction: the duty “does not require you to conduct a ‘periodic review’, or to provide credit assistance to the consumer in the future”, although it adds that reviewing circumstances from time to time is good practice, and that the duty applies to any credit assistance you do provide at that time.

So the honest summary is narrow. A hike on 3 November does not retrospectively put a sound August recommendation in question. What it does is change the facts available to you for any new piece of credit assistance you give after it, including a conversation where a client who went quiet comes back. Treat the distinction between those two things as the organising idea for the next fortnight, because it tells you which files to leave alone.

A six-day triage for your pipeline

You have the period between today and the Board’s decision. Used well, it is enough to sort a pipeline into three groups and spend your time on one of them.

1. Pull the list of unsettled approvals and their capacity headroom. Not the approval amount — the gap between the amount approved and the maximum the lender would have approved on the same inputs. Files with thin headroom are the ones a 25 basis point assessment rate move can touch. Files with wide headroom can be left alone.
2. Separate floor-assessed files from product-plus-buffer files. Where a lender is assessing at its floor and the floor sits above product rate plus 3 percentage points, a small product move may not change the assessment. Where the product rate drives it, it will. Your aggregator’s servicing tool or the lender’s own calculator will tell you which you are in.
3. Flag anything where credit assistance was provided more than about two months ago and the client has gone quiet. These are the RG 273.121 and .122 files. Make the call on whether the information is still reasonably current, document the reasoning either way, and remember the 90-day inquiry point in the RG 209 note.
4. Check pre-approval expiry dates against the decision date. A pre-approval expiring in the fortnight after 3 November will be reassessed on whatever assessment rate and expense benchmarks are live at that moment, not the ones that produced the original number.
5. Write the client message now, once, for the whole segment. Not a forecast. A short, factual note that the September CPI printed on 28 October, that the Board meets 2–3 November, that outcomes are not certain, and that you will contact them if their position changes. Sending it before the decision is a service act. Sending it after looks like reacting.
6. Decide your fixed rate position in advance. Not which way to advise — what information you need in front of you before you advise either way on a given file, and how you will record the comparison. RG 273.51 and .54 put cost high on the list of factors to prioritise, and RG 273.56 notes that the lowest interest rate is not necessarily the lowest cost option for all consumers once fees and offset or redraw features are counted.

What to watch next

Three things, in order of how much they will change your week. The Board’s decision on 3 November, and with it the November Statement on Monetary Policy, which will show whether the trimmed mean forecast path has been revised up from the August numbers. Then lender repricing, which will not arrive as a single event — expect fixed rates to move first and unevenly, and expect calculator and benchmark updates to follow at each lender’s own pace over the following weeks. Then the October monthly CPI, due in late November, which will say whether September was a fuel and rebate story or the start of something broader.

The takeaway

A 4.3% headline is a client conversation. A 3.6% trimmed mean against a 3.3% forecast is a pipeline problem, because it is the number that moves the cash rate, which moves product rates, which moves assessment rates by exactly the same amount on every file not already sitting on a floor. The compliance response is narrower than it feels: your past recommendations are judged at the point they were made, but the files that have been sitting are the ones where RG 273.121 asks you to think, and the file should show that you did. Six days is enough to find those files. It is not enough to find them after the fact.