Subscriber Review Process
According to operating requirement 14.7 of ARNECC’s Model Operating Requirements, PEXA is required to establish, implement, review and keep current a Subscriber Review Process to ensure Subscribers are complying with the Model Participation Rules (MPR).
This page gives you tools and information to help you complete the Subscriber Review Questionnaire.
FAQs
- Why does PEXA have to do a Subscriber Review Process?
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ARNECC’s Model Operating Requirements (MOR), operating requirement 14.7, requires PEXA to establish, implement, review and keep current a Subscriber Review Process to ensure Subscribers are complying with the Model Participation Rules (MPR).
- Who is ARNECC?
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The Australian Registrars' National Electronic Conveyancing Council (ARNECC) is the body established to facilitate the implementation and ongoing management of the regulatory framework for electronic conveyancing of real property in Australia.
- May I decline to participate in the review?
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No, Subscriber Managers who have been selected for this review need to complete the review within 30 days as a requirement posed in the MPR.
- What if I am deemed non-compliant?
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Subscriber Managers who have not been able to successfully outline how they comply with the MPR will be notified directly. PEXA will work with the affected Subscriber Manager to ensure appropriate actions are taken to remedy any identified gaps. In some cases, non-compliance may lead to suspension.
- What if I am not able to respond within the specified time frame?
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Contact details will be provided with the SRP questionnaire to discuss your options directly with PEXA.
- May I send the answers in batches?
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All participants are required to complete all sections of the Subscriber Review Process before submission. However, you can save your progress and return to complete this questionnaire at any time.
- Why was I selected?
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The process for selecting recipients of the Subscriber Review Process is random and based upon criteria previously agreed with ARNECC. Recipients include, but are not limited to Financial Institutions, Legal Practitioners, and Conveyancers.
- If I am selected now, will I have to do this again?
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Yes, as this is a requirement of the MPR, Subscriber reviews will be undertaken on an ongoing basis from May 2019. In this regard, you may be required to complete the review in a future cycle.
- Can the questionnaire be issued to another Subscriber Manager within your organisation?
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Yes, the questionnaire can be issued to another Subscriber Manager within your organisation. Should this be required, please send an email to SubscriberReviewProcess@pexa.com.au prior to commencing the questionnaire.
- Is there anything I need to do in order to prepare?
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We recommend a review and understanding of the MPR. This can be further supplemented by attendance in the webinar and reference to additional resources here on the e-Conveyancing Community.
- What if I disagree with PEXA's decision that I am non-compliant?
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A dispute resolution process is in place for Subscriber Managers who wish to challenge the decision. An email detailing the dispute can be submitted to: SubscriberReviewProcessDisputes@pexa.com.au. PEXA will respond to the email within 5 business days.
- How and when will I find out if I have passed / am compliant?
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Once you have submitted your completed review in a satisfactory manner, PEXA will notify you of your results within 10 business days.
- May I circulate the review internally?
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Yes, you may engage other experts within your organisation, however, the review will need to be submitted by a Subscriber Manager in your organisation.
- How will the Subscriber Review Process be carried out and what will PEXA be looking for?
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Subscriber Managers will be required to complete an SRP questionnaire on behalf of their organisation that will include questions on eligibility criteria (as defined in the MPR); general obligations; system security and integrity. Subscriber Managers will be requested to answer these questions within 30 days, and where necessary, to attach relevant evidence.
- When will the Subscriber Managers be alerted that they have been selected for the review?
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Subscriber Managers will be contacted 30 days prior to the due date of the assessment. They can choose to engage colleagues to respond to the questions but the completed assessment must be submitted by the Subscriber Manager.
- How does this review differ from others?
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The Subscriber Review Process differs from other assessments that Subscribers may have completed, such as compliance examinations conducted by land registries. PEXA is required by ARNECC to complete this review, which focuses on Subscriber obligations as outlined in the MPR.
* Please note, other obligations exist in relation to verifying identity, holding relevant evidence for a transaction, holding a client authorisation, providing certifications (among other things). These are not summarised here. This is not an exhaustive summary of your MPR obligations.
