Found by buyers. Referrals booked. File notes drafted.

Asked to recommend a local business in two Blue Mountains towns, an AI assistant named none at all.2 Type “mortgage broker” and Google suggests Penrith and Springwood.3

More than 5,500 credit representatives and 522 credit licensees carry an address across the thirteen councils, a third of every credit representative in NSW, against about 440 registered financial advisers.4 That is why this page leads with brokers.

A commission-paid licensee may not call itself independent, impartial or unbiased.5 ASIC names file notes, including records of conversations, among the records it expects to show the duty was met.8

An adviser’s ongoing fee consent runs on a 150-day clock we track but never draft.10 Your aggregator may already ship most of the rest: AFG and Connective’s Mercury Nexus both say so on their own pages, read 22 September 2026.9

1. Verified. Google’s AI features documentation, 10 December 2025: “There are no additional requirements to appear in AI Overviews or AI Mode, nor other special optimizations necessary.” The four things that get a page quoted are a controlled study of 252,000 trials, arXiv:2605.25517; our Get Found page carries it in full.
2. Measured by us. Two questions put to an AI assistant on 25 August 2026 for a Blue Mountains business: asked for the best agents in the Lower Blue Mountains it named two franchise brands and no local firm; asked who to use to sell a house in Glenbrook or Blaxland it named no local business at all. One day and two questions is a shape, not a benchmark, and the reason we re-run the questions monthly for every client.
3. Measured, and localised to one machine. Google’s public autocomplete endpoint with the Australian parameter, 16 September 2026, raw responses saved: “mortgage broker” returns Penrith and Springwood among its first completions, and “financial adviser” returns “financial adviser register” first. Penrith in England contaminates some completions here, so no single Penrith result is read as local demand. The randomised register is ASIC’s MoneySmart, Choosing a financial adviser, last updated 18 June 2026: “The search results are randomised and in no particular order.”
4. Measured, from the regulator’s own registers. ASIC’s Credit Representative, Credit Licensee and Financial Advisers datasets as published on data.gov.au, September 2026 extracts, downloaded and counted 16 September 2026: 5,506 current credit representatives and 522 approved credit licensees with an address in the thirteen councils, against 16,004 credit representatives in NSW, so 34.4%. Current registered financial advisers here: 442, against 4,434 in NSW. A credit representative is a person authorised by a licensee, not a business, so this is not a count of broking firms, and no such count exists.
5. Verified. National Consumer Credit Protection Act 2009 (Cth), Compilation No. 52, 1 July 2026, read 16 September 2026. s 160B: a licensee must not use “the word ‘independent’”, “the word ‘impartial’”, “the word ‘unbiased’” or another term “of similar import” in a representation to a consumer about itself or its service, with a civil penalty of 5,000 penalty units; the defence requires that the licensee receives no indirect remuneration at all, so a commission-paid broker does not meet it. That is a floor, not a cap: under s 167B the maximum for an individual is the greater of that or three times the benefit, and for a company at least ten times.
6. Verified. ASIC, Regulatory Guide 234, Advertising financial products and services (including credit), issued 9 June 2026, read 16 September 2026. RG 234.8: the guide applies to advertising in any medium “and it also applies regardless of any specific technologies that may be used, including artificial intelligence (AI)”, with the note that “the potential for hallucinated or biased content by AI tools may increase the risk of misleading or deceptive advertising”. RG 234.151 bars describing a service as comprehensive advice where the authorisation is narrow, and Example 64 bars “a wide range of lenders” where a broker uses one or two.
7. Verified. National Consumer Credit Protection Act 2009 (Cth), Compilation No. 52, 1 July 2026, read 16 September 2026. s 158LA: “The licensee must act in the best interests of the consumer in relation to the credit assistance”, civil penalty 5,000 penalty units, with no safe harbour set out. For advisers the equivalent duty is Corporations Act 2001 s 961B, which is structurally different: s 961B(2) gives a provider a safe harbour, satisfied by proving seven listed steps. Nothing automated answers a rate, a borrowing capacity, a product or a fee question, or anything about the enquirer’s own circumstances: those cross into credit assistance or advice.
8. Verified. ASIC, Regulatory Guide 273, Mortgage brokers: Best interests duty, 24 June 2020, read 16 September 2026: “The National Credit Act does not set out circumstances in which a mortgage broker is taken to have complied with these obligations”, and its record-keeping expectations name “relevant conversations with the consumer” and “file notes, including records of conversations”. Nothing automated sets, estimates or describes the fee or the services: the draft comes from the practice’s own numbers and the signature is chased.
9. Verified. AFG (afgonline.com.au), read 22 September 2026: Suite360 as “your single stop for broker technology”, BrokerEngine Plus for deal lodgement, customer management and product selection, and SMART’s “branded campaigns, emails and a well-designed website that will grow your audience and attract more customers - all without lifting a finger”. Connective’s Mercury Nexus (connective.com.au/mercury-nexus), read the same day: lead capture, credit checks, open banking, borrowing capacity calculators, compliance workflows and DigiSign e-signing built in, keeping clients “engaged with branded emails and SMS messages”. Which plan includes each feature was not checked.
10. Verified. Corporations Act 2001 (Cth), compilation read 16 September 2026. s 962F terminates an ongoing fee arrangement where a complying consent is not given; s 962H gives the consent a life of 150 days, renewable in a window opening 60 days before the anniversary day and closing 150 days after it. The Delivering Better Financial Outcomes reforms will change parts of this and were still draft at that compilation, so this note carries a recheck date in tools/rechecks.json.