How we supervise our authorised representatives.

Appointment

At appointment

We diligence each applicant before we appoint it. We review the proposed business, the people, the target investors and the documents. Responsible managers must meet the knowledge and skill standards in RG 105.

Authorisations are scoped to the agreed business. We do not take on CAR mandates as a regulatory shortcut.

Before appointment, each CAR completes two to four hours of mandatory initial training. We notify ASIC of the appointment.

Monthly

Every month

Each CAR submits a monthly compliance pack. We give written findings within five business days.

Marketing

Marketing approvals

Every piece of marketing material is reviewed before use. We review each item within two business days.

An information memorandum review and licensee clearance takes ten business days, and five for later revisions.

Incidents

Breaches and incidents

We acknowledge an incident the same business day. We start a breach assessment within two business days.

Where a matter is a reportable situation under s912DAA of the Corporations Act, we report it to ASIC within the time the Act requires.

Cadence

Every quarter and every year

We hold a compliance meeting with each CAR every quarter. It covers critical events, policy reviews and reportable situations.

Each CAR has an annual review, including fitness and the training register. Our own s912A obligations are signed off on a set cycle.

People

Our compliance team

Mark Wist leads compliance delivery. The team is Matthew Bode, Mark Wist, Gavin McInnes, Ray Morgan, Brad Burns and Graeme MacLaren. Together they bring almost 200 years of combined experience in law, finance and funds management, valuation and compliance.

Responsible managers: Graeme MacLaren and Gavin McInnes.

Governance

Governance

• Two independent directors, neither associated with GRM LAW.
• A compliance committee.
• Responsible managers who meet RG 105.
• Two-to-sign execution of documents.
• SLC takes no origination, distribution or success economics from the funds it supervises.

Capacity

Capacity

We cap new appointments to what our compliance team can supervise. We take on no more than five new CARs in any 12-month period. We currently supervise five CARs.

Fit

Who we appoint

We appoint managers that:

• deal only with wholesale clients;
• run a wholesale property development or secured-lending strategy, or another strategy we can diligence;
• have an executable investment policy and a clear investor profile;
• have responsible managers who meet RG 105; and
• accept SLC as trustee and issuer of the fund.

Perimeter

Who we do not appoint

• Managers seeking to deal with retail clients.
• Lending to consumers. SLC does not hold an Australian Credit Licence.
• Managers seeking a CAR appointment to avoid regulatory scrutiny.
• Managers who want to issue their own product as principal outside our trustee structure.
• Managers whose people do not meet RG 105.

Disclosure

Our relationship with GRM LAW

Gavin McInnes, SLC’s Managing Director, is Founding Partner of GRM LAW. GRM LAW may act as solicitors on fund and CAR documents. You may nominate your own lawyers where there is no conflict.

Related-party dealings with GRM LAW are notified to our compliance committee and managed under a conflicts policy aligned to RG 181.

REP 820

Alignment with ASIC Report 820

In November 2025 ASIC published Report 820, which sets out ten principles for private credit funds. Principle 2 concerns organisational capability, including monitoring and supervising CARs. The framework on this page is how we address it.

We can show any CAR, in writing, how its fund measures against the ten principles.