TL;DR
- ING Australia self-reported material miscalculations of its liquidity position to APRA in July, covering several years of reporting.
- Its reported Liquidity Coverage Ratio was around 160 per cent. The true figure was substantially lower and at times fell below the 100 per cent minimum required under Prudential Standard APS 210.
- APRA imposed licence conditions requiring independent reviews of the reporting failures and of broader risk management and governance.
- APRA also raised ING Australia's minimum liquidity requirements while that review work is completed.
- APRA describes ING Australia as financially resilient, but still called the breaches serious.
A bank reported the wrong number for years. Nobody caught it until the bank caught it itself.
What actually happened, and why should a broker care?
APRA published details of its action against ING Australia on 3 September 2026. ING Australia was reporting a Liquidity Coverage Ratio of around 160 per cent. Its true LCR was substantially lower, and at times dropped below the 100 per cent minimum required by Prudential Standard APS 210. In July, ING Australia told APRA it had found material miscalculations of its liquidity position covering several years.
APRA's response was measured but firm. It imposed licence conditions requiring independent reviews of both the reporting failures and the bank's broader risk management and governance. It also raised ING Australia's minimum liquidity requirements while that work is underway. APRA says it views the bank as financially resilient. It still called the breaches serious.
For a broker, the banking mechanics are not the point. The point is that a regulated institution with dedicated compliance teams and a regulator watching it closely still managed to report a materially wrong number for several years. The error was found internally, not by any external check.
Is your brokerage running numbers nobody has verified in a while?
Every broker operation produces numbers. Pipeline values, conversion rates, compliance checklists, call volumes, client contact logs. Many of those numbers come from software: a CRM, a broker platform, a spreadsheet that has been copied and pasted since before the current admin started.
The ING Australia situation is a useful prompt to ask a simple question: when did someone last verify a key number by hand, against the original source, rather than trusting what the system reported?
This is a process problem, not a technology problem. ING Australia's miscalculation was caused by a methodology that was wrong, and a reporting process that passed the wrong output upward without catching it. The same pattern appears in broker businesses when a CRM field is mapped incorrectly, when a compliance log auto-populates from a field that stopped updating, or when a call disposition is recorded by an AI agent in a category that no longer matches the workflow it was built for.
For brokers thinking about AI agent deployments, the risk is real. An AI voice agent that logs call outcomes, qualifies leads, or updates client records is producing data that will eventually inform decisions. If the agent's output is never spot-checked against reality, the brokerage is in the same position ING Australia was in: confident in a number that has not been verified. The post Agent Validation: Stop Before You Book, Charge, or Send covers exactly this point for broker AI deployments.
What did APRA actually require, and what does that tell a broker about governance?
APRA's licence conditions have two components. First, independent reviews of the reporting failures and of risk management and governance more broadly. Second, a raised minimum liquidity requirement while that work is done. The regulator is not just asking ING Australia to fix the number. It is asking the bank to explain how the wrong number survived for so long, and to demonstrate that the governance structures around reporting are sound.
ASIC and APRA both expect that regulated entities can explain not just what their numbers are, but how those numbers are produced and checked. A broker who relies entirely on a platform's output without any independent verification step is exposed if that output turns out to be wrong.
The CSLR levy situation is a different but related example of regulatory cost landing on brokers because of systemic failures elsewhere. That context is covered in Draft CSLR Special Levy: Why Brokers Are Facing a Bill That Is Not Theirs to Pay. The pattern is consistent: when governance fails somewhere in the financial system, the cost distributes broadly.
What a broker should actually do
Three practical steps are worth taking.
First, identify the two or three numbers your brokerage reports most often, whether to a licensee, a lender, or internally, and trace each one back to its source. Confirm the calculation is still correct.
Second, if you use any automated system to produce compliance or operational data, schedule a manual check of a sample of that output against the underlying records. Do this quarterly at minimum.
Third, document the methodology. If someone asked you today how a particular metric is calculated, could you explain it without opening the software? If not, that is the gap to close.
The full APRA notice is available at apra.gov.au.
FAQs
What did APRA find wrong with ING Australia's liquidity reporting?
ING Australia self-reported to APRA in July that it had found material miscalculations of its liquidity position covering several years. Its reported Liquidity Coverage Ratio was around 160 per cent, but the true figure was substantially lower and at times fell below the 100 per cent minimum required under Prudential Standard APS 210.
What action did APRA take against ING Australia?
APRA imposed licence conditions requiring independent reviews of the reporting failures and of the bank's broader risk management and governance. It also raised ING Australia's minimum liquidity requirements while that review work is completed. APRA described the breaches as serious despite viewing the bank as financially resilient.
Why does an ING Australia liquidity breach matter to a mortgage broker?
The direct banking impact is limited for most brokers. The relevant lesson is that a regulated institution with significant compliance resources still reported a materially wrong number for several years without external detection. Any broker operation that relies on automated or system-generated data without periodic manual verification faces a similar risk at a smaller scale.
How should a broker check whether their compliance data is accurate?
Start by identifying the key numbers your brokerage reports most often and tracing each back to its original source. Run a manual spot-check of any automated system output against underlying records. Document the methodology so the calculation can be explained and reproduced without relying on the software alone.
Does this affect which lenders a broker can recommend?
APRA states it views ING Australia as financially resilient, and the bank has raised its liquidity well above the minimum. The licence conditions relate to governance and reporting reviews, not to the bank's ability to write loans. Brokers should monitor APRA's public register for any changes to ING Australia's licence status.
Originally published at theautomate.io.
Top comments (0)