EOFY Sale · Save up to $750 off your legals · Ends 30 June

Claim offer
Selected cases

Federal Court of Australia · [2026] FCA 506

ASIC v Money3

A Federal Court penalty case about responsible lending inquiries, expense verification and a $1.55 million penalty against Money3 Loans.

Federal Court of Australia27 Apr 2026

Plain-English explainers, not legal advice. Check the linked official source before you rely on a specific section, and get advice for your situation.

Get legal help

Start here

Quick read

  • Responsible lending checks cannot be a box-tick.
  • A Federal Court penalty case about responsible lending inquiries, expense verification and a $1.55 million penalty against Money3 Loans.

Use this to check

  • Responsible lending procedures need to match the actual approval workflow.
  • Bank transaction data should be reviewed, not merely collected.
  • Policies and training are weak evidence if staff do not apply them in real assessments.

Decision snapshot

  1. 1

    What happened

    • ASIC brought responsible lending proceedings against Money3 Loans.
    • A 2025 liability judgment found limited contraventions relating to five credit contracts entered into with six consumers between May 2019 and February 2021.
    • The failures included not making reasonable inquiries about declared living expenses by using bank transaction data Money3 had obtained, not taking reasonable steps to verify those expenses, and, for two consumers, not asking whether finance was actually sought for an application fee and brokerage.
  2. 2

    What the court had to decide

    • The Court had to decide the appropriate penalty for contraventions of responsible lending inquiry and verification obligations under the National Consumer Credit Protection Act.
  3. 3

    What the court decided

    • The Federal Court ordered Money3 to pay a $1.55 million civil penalty.
    • ASIC's proposed compliance order relief was refused, and costs were left for later determination.

Practical impact

Practical read

  • Responsible lending checks cannot be a box-tick.
  • If a lender has bank transaction data, declared expenses and warning signs, it needs a real process for inquiries and verification before entering the credit contract.

Useful next steps

  • Responsible lending procedures need to match the actual approval workflow.
  • Bank transaction data should be reviewed, not merely collected.
  • Policies and training are weak evidence if staff do not apply them in real assessments.
  • Map each credit decision to the documents and data actually reviewed.
  • Give analysts practical examples of what must be checked in bank transaction data.

Practical read

Money3 is a lender compliance case, but the lesson is wider than lending. A business can have policies, training slides and data in front of staff, yet still fail if the actual workflow does not make people use that information properly.

The Court treated the contraventions as serious because responsible lending rules are designed to protect consumers. At the same time, the judgment is careful about the facts: ASIC did not prove every allegation, the contracts were not found to be unsuitable, and Money3 had not previously been found to have similar contraventions.

The penalty was $1.55 million. For credit providers, brokers and finance-adjacent startups, the case is a reminder to test what analysts or sales staff actually do with bank statements, expense declarations, fees and warning signs before a contract is made.

Checks to run

Key points

  • Map each credit decision to the documents and data actually reviewed.
  • Give analysts practical examples of what must be checked in bank transaction data.
  • Require follow-up where expenses, fees, brokerage or unusual transactions need explanation.
  • Audit a sample of approvals against the policy, not only against system completion fields.

Key takeaways

  • Responsible lending procedures need to match the actual approval workflow.
  • Bank transaction data should be reviewed, not merely collected.
  • Policies and training are weak evidence if staff do not apply them in real assessments.

Related topics

Finance, Payments & SecurityConsumer Law & Trading

How Sprintlaw can help

Regulatory ComplianceContract Review