The passage of the National Consumer Credit Protection Act late in 2009 was the catalyst for a review of business strategies in the loan broker and aggregator markets. The industry is now faced with higher compliance costs, stricter service obligations and higher barriers to entry, on top of already shrinking commissions.Commentators expected significant consolidation, but saw opportunities for groups that were in a position to grow through mergers or could offer services to brokers who might be struggling with regulatory requirements.But, so far, it has been business as usual. The number of brokers leaving the industry has been fewer than expected, and groups that established new business models on the assumption there would be a lot of consolidation have not really got going yet.According to the industry's peak body, the Mortgage and Finance Association of Australia, broker numbers will fall about five per cent this financial year. The MFAA's membership has fallen 13 per cent, from 13,800 before the financial crisis to 12,000 now.MFAA's chief executive, Phil Naylor, said the reduction over the past few years was due to lower demand for finance and smaller broker commissions, as well as the burdens imposed by the NCCP.He said there would be further consolidation after July 1, when anyone operating in the consumer credit market will have to have an Australian Credit Licence or an authorisation from a licensee.The chief executive of the aggregator Vow Financial, Tim Brown, said many brokers and aggregators were still operating on the basis that it was business as usual. "When we do audits of our people we come across a lot of compliance issues. They have not caught up with what they need to be doing under the new regime."Like Naylor, Brown believes there are a large number of brokers still to exit the industry. But, in the meantime, Vow's business is slowly developing.Vow was formed last year through the merger of three smaller groups. Brown, who was appointed earlier this year, said the group was not at the scale it should be. He has a two-pronged strategy: find more groups to merger with Vow; and convert the company into a broader financial services group.Brown said he was in talks with three aggregators about mergers.Earlier this month, Vow signed a joint venture agreement with a financial planning group, Selector, which will set up a business called Vow Wealth. Vow brokers will be encouraged to refer their clients to Vow Wealth for investment advice.Brown said no aggregator or broker had yet managed to expand into broader financial services successfully. He said: "Some are getting five per cent or so of their revenue from the investment side, but no one has achieved anything like a 50/50 split. "There was no great need to get this right before, but there is now. Traditional broker income is more at risk. "We are encouraging our brokers to come and work in a series of regional offices that we are setting up. The aim is to get the brokers mixing with the