One Big Switch, the organisation running consumer group Choice's "Big Bank Switch", has suggested to lenders that it will not be legally required to make costly credit assessments of its members.One Big Switch (OBS) made the suggestion in an Expression of Interest document distributed to lenders and obtained by Banking Day.The document also sets a deadline of this Friday, August 26, for lenders to respond to OBS's Request for Proposal. Discussions with short-listed lenders will begin next Monday. The dates for signing up lenders, presenting offers to members and completing member applications and approvals have been left blank.And the Expression of Interest document says lenders must make offers that are exclusive to OBS's 40,000-plus members.One Big Switch has been controversial in part because of Choice's perceived conflict of interest, its use of the Choice name to drive a commission-earning deal, and the lack of information on how the arrangement between Choice, OBS and lenders will work.The Mortgage Finance Association of Australia, the mortgage-broking industry's lobbyist, has asked Australian Securities and Investments Commission to investigate whether OBS is acting within the confines of the National Credit Act.The document helps explain how OBS plans to navigate the National Credit Act legally without the need to assess each member's credit requirements. It declares that "OBS will not be acting on behalf of or providing credit assistance" to its members, noting that it uses the phrase "credit assistance" with the same meaning it has in the act.If OBS does not act on behalf of members or provide them with credit assistance, a reading of the act suggests it will not be legally obliged to follow the responsible lending guidelines of the act, and will thus avoid the need to make detailed credit assessments.The document says lenders will have to meet responsible lending obligations to members they finance under the Big Bank Switch.The Expression of Interest document asks for "exclusive group discount offers to OBS members, subject to loan qualification, for limited offer periods." OBS expects offers to remain open for up to two weeks.OBS is looking for discounts on home loans across seven categories and "multiple geographic markets". The categories cover three loan value ranges and three different ranges of loan-to-valuation ratios.The document also states that OBS members are expecting "a reduction of the total loan cost of an equivalent publicly available loan offered by the lender.""This represents a tremendous opportunity for lenders to increase their market share, broaden their customer base and raise profile in the market," it says.In his latest blog post, on the Choice website, Choice chief executive Nick Stace said that ASIC had not begun any formal inquiry into the Big Bank Switch, despite a report in the Australian Financial Review last week that said the regulator was "inquiring" into the deal.