The Australian Securities and Investments Commission has advised credit providers that they may not need to participate in the new comprehensive credit reporting system in order to meet their responsible lending obligations.Since CCR was introduced in March, a question that has come up regularly at conferences is whether lenders need to invest in the new system and gain access to more detailed credit files. At the Australian Securities and Investments Commission annual forum in March, Citigroup's head of consumer compliance, Michael Saadat, said lenders that did not have access to comprehensive credit files could be "vulnerable" if a dispute about the suitability of a loan went to an ombudsman.Saadat said: "If a lender is not doing comprehensive reporting and then makes a credit decision that would have been different if the lender did have access to a comprehensive file, then what is the position if a dispute goes to an ombudsman?"If the decision would have been different, taking the extra information about the customer into account, it creates a vulnerability for the lender."However, Dun & Bradstreet's director of consumer risk solutions, Steve Brown, said he attended an industry forum earlier this month at which a senior ASIC officer said CCR was not needed to meet responsible lending obligations.ASIC was a bit more circumspect when Banking Day called for confirmation. A spokesman said the regulatory guide covering responsible lending (RG 209) "does not mandate the use of credit reporting information when undertaking a credit assessment process".ASIC's position is that a consumer's credit file is the type of information that could be used to verify their financial situation. Reasonable inquiries about a consumer's financial circumstances could include inquiries about their credit history, "although those inquiries could be made directly of the consumer and not necessarily by accessing a credit file."However the guide also says it would "generally be reasonable" for a lender (but not necessarily a credit assistance provider) to obtain a consumer credit report.Under the responsible lending rules of the National Consumer Credit Protection Act, a financial services provider must do three things to be satisfied that a credit contract is "not unsuitable" for a borrower: it must make reasonable inquiries about the consumer's requirements and objectives; it must make reasonable inquiries about the consumer's financial situation; and it must take reasonable steps to verify the consumer's financial situation.Another speaker at the ASIC forum, the lead ombudsman in the banking and finance division of the Financial Ombudsman Service, Philip Field, said: "One of the positives of comprehensive reporting is that it allows you to make a better assessment of the borrower's capacity."But credit history is not the only way to make sure a borrower can manage a loan without difficulty."I have spoken to some lenders who say they have enough information and the cost of getting into the comprehensive reporting system may not be worth it."I don't think it is absolutely necessary for lenders to join the top tier to satisfy their responsible lending obligations."