ASIC plans to tighten its guidelines for responsible lending conduct, as concerned as ever that some licensees are not taking sufficient steps to meet their obligations. And it wants to bring the guidelines up to date to take account of developments such as comprehensive credit reporting.The regulator has issued a consultation paper, outlining changes to its guidelines on responsible lending, Regulatory Guide 209, which has been in force since 2010.The consultation paper says: "Although the law has not changed since 2010, ASIC considers it timely to review and update the guidance in light of its regulatory and enforcement work since 2011, changes in technology and the recent final report of the Royal Commission."One item up for consideration is whether to "more clearly identify the inquiries and steps that we think are important for licensees in complying with their responsible lending obligations."That would include guidance on the kinds of information that could be used for verification of the consumer's financial situation, including a list of forms of verification.RG 209 does not specify minimum standards. Obligations are scalable, with process left up to the licensee.Now ASIC is concerned that this approach may not be rigorous enough. It says: "We have observed since the start of the responsible lending regime instances where licensees have failed to take sufficient steps in order to comply with their obligations."As to the steps that need to be taken, ASIC says it may need to state more clearly that it is not sufficient to obtain verifying information but not have regard to it.Developments in relation to open banking, comprehensive credit reporting and data aggregation services will affect the accessibility and cost of obtaining transaction information are also up for consideration.With the inclusion of repayment history information in comprehensive credit reporting, ASIC will issue guidelines on how that information should be used. It says: "The occurrence of repayment difficulties on one product will not necessarily mean that a new credit product will in all cases be unsuitable for the consumer, this information should instead trigger the licensee to make more inquiries to enable them to understand these repayment difficulties and the likelihood that the circumstances would mean that the consumer could not meet financial obligations in future."ASIC is also planning to clarify its guidance on the use of benchmarks. It says they can be a useful tool to determine whether the information provided by the consumer is plausible. However, lenders should not default to a benchmark as a substitute for making inquiries.And it wants lenders to have a better understanding of the rationale for the loan, so they can assess whether a credit contract will meet the consumer's requirements. It says lenders and brokers often identify a "high-level" purpose for the credit but this does not meet the obligation to inquire about the consumer's objectives and requirements.