Legal Entity Structure
Entity Comparison
- Low setup cost (~$50 to $200)
- Simple governance structure
- Cannot apply for DGR Item 1 status directly
- Restrictions on operating nationally across all states
- Limited credibility with institutional donors
- State-by-state registration required for national operations
- ACNC registration eligible
- DGR Item 1 (General Deductible Gift Recipient) eligible
- PBI (Public Benevolent Institution) eligible
- National operation from a single registration (ASIC)
- Tax exemptions: income tax, FBT, GST concessions
- High credibility with philanthropic trusts and foundations
- Members have limited liability - no share capital
- ASIC registration fee: $512 (payable directly to ASIC). No solicitor required — founders lodge Form 201 directly using CoSai-prepared documentation.
- DGR and PBI eligible
- Lower ongoing compliance requirements
- No members - governed by trustees only
- Cannot take on employees directly (requires a corporate trustee)
- Difficult to amend trust deed once established
- Less suited to service-delivery organisations
Recommended Structure: Two-Entity Model
Entity 1 - The Charity
Life Without Debt CLG
Type: Company Limited by Guarantee
Status: ACNC registered charity
Endorsements: DGR Item 1, PBI
Purpose: Receives donations, provides free services to clients, employs most staff
Regulator: ASIC (corporate), ACNC (charitable)
Entity 2 - The Licensed Practitioner
Credit Mediation Services Pty Ltd
ACL No. 387398
Type: Existing Pty Ltd (commercial)
Role: Provides licensed credit mediation practitioner services for cases referred by the charity
Arrangement: Service agreement with the CLG
Principal: Laurence Hugo (Technical Negotiator)
Registration Project Plan
The registration sequence must follow a specific order. ACNC registration must be completed before ATO endorsement applications (DGR and PBI) are lodged. ASIC incorporation precedes ACNC registration.
ASIC Incorporation - Company Limited by Guarantee
- Draft and review Constitution (CLG specific - no share capital, members have limited guarantee liability)
- Constitution must specify: charitable purpose, dissolution clause (surplus assets to another charity), name reservation
- Appoint founding directors (minimum 3 recommended for ACNC governance purposes)
- Register with ASIC - Form 201 (Application for registration as an Australian company)
- ASIC registration fee: $512 (2025 rate for CLG)
- Obtain ACN (Australian Company Number)
- Apply for ABN immediately after ACN issued (via ABR - free)
ACNC Registration - Australian Charities and Not-for-profits Commission
- Submit ACNC registration application online at acnc.gov.au
- Purpose must meet one of the charitable purposes under the Charities Act 2013 (s12)
- Relevant purpose: "advancing social or public welfare" - explicitly covering relief from debt burden in terminal illness
- Submit Constitution, statement of charitable purpose, financial projections
- Nominees must disclose any related party relationships (Laurence Hugo as director of Credit Mediation Services Pty Ltd is a disclosable related party)
- ACNC registration is free of charge
- Upon approval: ACNC charity number issued, organisation listed on ACNC Register
ATO Tax Endorsements - DGR and PBI
- DGR Item 1 (Public Fund): Apply via ATO Business Portal. Enables tax-deductible donations to donors. Requires establishment of a Public Fund with a gift fund account separate from operating accounts.
- PBI Status (Public Benevolent Institution): Apply simultaneously with DGR. PBI endorsement provides additional tax concessions including FBT exemptions (up to $30,000 per employee per year) and GST concessions.
- PBI test: organisation must be "benevolent" (relieving poverty, sickness, or suffering) and "public" (serves a wide enough section of the community). Terminal illness debt relief clearly meets both tests.
- Income Tax Exemption: apply at same time as DGR - will be assessed as a registered charity
- GST Concessions: apply separately via ATO once DGR/PBI confirmed
Service Agreement - Credit Mediation Services Pty Ltd
- Draft formal service agreement between Life Without Debt CLG and Credit Mediation Services Pty Ltd (ACL 387398)
- Agreement to specify: scope of services, referral protocol, cost recovery or in-kind arrangement, confidentiality, ACNC related party disclosure obligations
- Reviewed by solicitor to ensure arm's length nature and ACNC compliance
- Board approval required before execution
- Disclosed in ACNC Annual Information Statement as a related party transaction
Ongoing Compliance Obligations
- ACNC Annual Information Statement (due 31 January each year, or within 6 months of financial year end)
- ASIC Annual Company Statement (due on anniversary of incorporation)
- ATO: income tax return lodgement (or confirmation of exemption)
- Maintain ACNC governance standards (Standard 1 to 9)
- Board meetings: minimum 4 per year with written minutes
- Related party transactions: disclosed in annual report
- Financial audit: required once annual revenue exceeds $1,000,000
Organisational Chart
Minimum 3 at incorporation
(Negotiator)
Role Descriptions and Market Salaries
Salary benchmarks are based on 2024 to 2025 Australian market data sourced from the SCHADS Award, Seek Salary Insights, and NFP-specific benchmarking. All salaries shown are base remuneration (excluding super, leave loadings, and any FBT-exempt benefits). Superannuation is an additional 11.5% (SG rate).
Chief Executive Officer (Operations & Strategy Lead)
Laurence Hugo. Chief Executive accountable to the Board for end-to-end charity performance: strategy, operations, fundraising, stakeholder management, and Theory of Change delivery. The CEO is the sole executive officer of the CLG and brings direct experience operating under an Australian Credit Licence (CMS Pty Ltd, ACL No. 387398) — the operating discipline that underpins LWD's credit-representative model.
Key Responsibilities
- Lead the day-to-day operational functioning of Life Without Debt, including staff oversight, case workflow management, and service delivery quality
- Develop and implement the organisation's annual strategic plan in consultation with the Board of Directors
- Manage all external stakeholder relationships: referral partners, healthcare networks, oncology social workers, palliative care teams, and donor contacts
- Oversee financial management and reporting in collaboration with the bookkeeper and auditor, and ensure ACNC compliance obligations are met
- Lead the organisation's fundraising strategy, including grant writing, donor cultivation, and corporate partnership development
- Act as primary liaison between the Board and the operational team, preparing board reports and board meeting materials
- Manage the service agreement relationship with Credit Mediation Services Pty Ltd and ensure related party obligations are met
- Build the organisation's public profile and represent it in media, sector forums, and government consultations
Qualifications and Experience
- Demonstrated experience in not-for-profit management, community services, or a related sector
- Strong understanding of Australian charity governance and ACNC compliance requirements
- Proven ability to manage small teams, external contractors, and volunteer relationships
- Experience with grant applications and philanthropic fundraising
- High emotional intelligence and capacity to work sensitively with people in terminal illness situations
- Strong written and verbal communication skills
- Financial literacy sufficient to understand and present management accounts
Salary Benchmark Reference
- ACOSS NFP CEO Remuneration Survey 2024 (revenue band $1M–$5M): $145,000 to $185,000 base
- Pro Bono Australia Salary Survey 2024 (DGR charity CEO, growth phase): $150,000 to $200,000 base
- Comparable founding-CEO roles (Foodbank, Beyond Blue early-stage, Anglicare): $160,000 to $190,000 base
- Recommended Board-approved rate: $165,000 base (midpoint of the CEO's authorised range $150,000–$180,000), set by the Board’s Remuneration sub-committee with reference to the comparator survey above. Indexed at 3% p.a. and reviewed against external benchmark every two years.
- Justification: the CEO is solely accountable for executing a 10-year growth plan from $470K to $100M annual revenue, signing all major funder agreements, managing the 7-Room funding portfolio, and carrying ACNC responsible-person liability. The role is materially larger than a community-services manager benchmark and is paid accordingly.
Technical Negotiator
Laurence Hugo. Licensed credit mediation specialist under ACL No. 387398, contracted via Credit Mediation Services Pty Ltd.
Key Responsibilities
- Conduct all licensed credit mediation activities on behalf of the charity's clients, operating under Australian Credit Licence No. 387398 held by Credit Mediation Services Pty Ltd
- Assess and review each referred client's debt situation, identify applicable legal frameworks (hardship provisions, ATO payment arrangements, debt waiver mechanisms), and develop case strategies
- Negotiate directly with creditors (banks, ATO, private lenders, debt collectors) on behalf of clients to achieve debt waiver, reduction, or structured resolution
- Prepare all formal creditor correspondence, hardship applications, and supporting documentation in accordance with the National Consumer Credit Protection Act
- Provide written case updates and outcomes data to the Operations and Strategy Lead for reporting and quality assurance purposes
- Advise on estate debt planning for clients approaching end of life, including communication with executors and family members where authorised
- Maintain compliance with all ACL obligations including responsible disclosure, internal dispute resolution, and ASIC reporting requirements
Qualifications and Licencing
- Australian Credit Licence No. 387398 - Credit Mediation Services Pty Ltd (current and active)
- Demonstrated expertise in consumer credit law, hardship provisions under the National Consumer Credit Protection Act 2009
- Extensive experience negotiating with ATO, major banks, and non-bank lenders on behalf of individuals
- Knowledge of the AFCA (Australian Financial Complaints Authority) process as a creditor escalation pathway
- Capacity to manage a pipeline of active cases simultaneously
Contract Rate Benchmark
- Senior credit mediator / financial counsellor (private sector): $100,000 to $140,000
- ACL licence holder providing contracted services: $110,000 to $130,000
- Recommended rate: $120,000 (contracted, not employed; no super liability on the CLG)
Community & Medical Liaison
Lisa Hugo. Co-founder role focused on building LWD's referral pipeline inside hospitals, oncology units, palliative-care teams and disease-specific peak bodies. Plays to Lisa's existing networks in the medical sector from her previous business.
Key Responsibilities
- Identify and approach hospitals, oncology social-work teams, palliative-care units and community-health services to establish formal referral pathways into LWD
- Build relationships with disease-specific peak bodies (Cancer Council, Heart Foundation, Dementia Australia, MS Australia, Parkinson's Australia, Kidney Health Australia, Lung Foundation, Diabetes Australia and similar) for both client referrals and co-branded fundraising
- Maintain a CRM of clinical contacts, referral MOUs and pilot agreements; track referrals-to-cases conversion as a measurement output
- Co-design clinician-facing materials with the CEO and Communications Officer (one-pagers, intake QR posters, in-service slide decks)
- Represent LWD at clinical conferences, AHHA/AHCA events and palliative-care forums
- Feed referral data into the Theory of Change measurement framework so funders can see the medical-referral funnel quarter-on-quarter
Qualifications and Experience
- Demonstrated network across Australian hospitals and the medical / allied-health sector (the qualifying experience here is Lisa's prior business activity)
- Senior relationship-management and business-development experience
- High emotional intelligence and ability to work with patients, clinicians and bereaved families
- Strong written and verbal communication; comfortable presenting to clinical teams
Salary Benchmark Reference
- NFP partnerships / clinical-engagement manager: $85,000 to $110,000 base
- Healthcare BD / liaison roles (oncology & palliative networks): $90,000 to $115,000 base
- Recommended rate: $95,000 base (midpoint), reviewed at Year-2 caseload milestone
Client Case Officer UPDATED 2026 · Cradle-to-grave
First hired employee in Year 1. This is a single combined role covering intake, case management, client liaison and supporting creditor correspondence — what was previously split between an Intake Coordinator and a Case Manager. The first person a client speaks to stays with them from cradle to grave: rapport, trust and case context all live in one head. Where the role-holder has the right experience and licensing, they may also act as a Credit Representative on negotiation; otherwise, they pair tightly with the Negotiator while owning the client relationship throughout.
Key Responsibilities
- Single point of contact: Be the named case officer the client speaks to from first call through to creditor resolution and 30/90-day post-close follow-up — not handed off mid-journey
- Intake & triage: Manage the online application queue, triage for urgency and eligibility, and make initial contact within 2 business days
- Document collection: Collect supporting documents from the client — bank statements, payslips, Centrelink statements, medical reports, hardship evidence, creditor letters — and load them into the case management system (this is the new Stage 2 of the Theory-of-Change journey)
- Case management: Maintain case notes, document storage, status tracking and SLA timers across the full caseload
- Creditor correspondence: Draft and send creditor letters under the supervision of the Negotiator. Where qualified and AFCA-registered, conduct first-line negotiation directly
- Client liaison: Provide regular progress updates and absorb the emotional weight of clients in terminal illness or significant distress
- Reporting: Generate monthly intake-to-resolution statistics for the CEO and Theory-of-Change measurement framework
Qualifications and Experience
- Diploma or degree in financial counselling, community services, social work, law, or related field
- Working knowledge of Australian consumer credit law, NCCP hardship obligations and ATO arrangements
- Minimum 2 years of experience in a client-facing case-management or financial-counselling role
- Demonstrated ability to communicate with empathy in sensitive situations
- Capacity to hold a caseload of 25–35 active matters with the same person owning each
- Eligible to be appointed and trained as a Credit Representative under an ACL (LWD intends to register Case Officers with AFCA as Credit Reps)
Salary Benchmark Reference
- SCHADS Award Level 4 to 5: $64,000 to $78,000
- Financial counsellor (NFP sector): $65,000 to $80,000
- Recommended rate: $72,000 base — premium reflects the combined intake + case-management scope and AFCA Credit-Rep responsibilities
Compliance Officer (Part-Time) NEW · Year 2 hire
Part-time role activated in Year 2. LWD is top-heavy on compliance — Licence holder, Credit Representatives registered with AFCA, NCCP training obligations, ACNC reporting, plus charity-governance requirements. A dedicated part-time compliance owner protects the licence and the Board.
Key Responsibilities
- Own the NCCP compliance schedule — periodic training for all staff acting as Credit Representatives, plus refresher training for the CEO and Negotiator
- Maintain the Credit-Representative register, AFCA notifications, ASIC notifications and the responsible-person records under the ACL
- Operate the Internal Dispute Resolution (IDR) process and oversee escalations to AFCA
- Prepare ACNC Annual Information Statement inputs and track responsible-person and conflict-of-interest declarations
- Run an annual compliance audit and prepare the Board compliance report each quarter
- Lead the LWD-own ACL application workpapers in Year 2 (see Section 10 — Year 2 Licence Roadmap)
Qualifications and Experience
- Demonstrated experience in financial-services or credit-licence compliance (NCCP, ASIC RG 205, ASIC RG 206)
- Familiarity with AFCA membership obligations and the IDR/EDR framework
- Working knowledge of the ACNC Governance Standards
- Diploma or higher in compliance, law, accounting, or financial services
Salary Benchmark Reference
- Compliance officer (small ACL, part-time): $70,000 to $90,000 FTE
- NFP / charity compliance manager: $75,000 to $95,000 FTE
- Recommended rate: $80,000 FTE × 0.6 = $48,000 in Year 2; reviewed to 0.8 FTE in Year 3 once LWD's own ACL is active
Operating Expense Budget
The budget below represents the annual steady-state operating expenditure once the organisation is fully operational. Year 1 will be lower as several roles will not be filled until mid-year or Year 2. All figures are in Australian dollars excluding GST.
| Line Item | Description | Year 1 ($) | Year 2 ($) | Year 3 ($) |
|---|---|---|---|---|
| People Costs | ||||
| Chief Executive Officer | Laurence Hugo — base salary (Board-approved, range $150K–$180K, set at $165K midpoint) | 165,000 | 169,950 | 175,049 |
| Superannuation (11.5%) | CEO super contribution | 18,975 | 19,544 | 20,131 |
| Community & Medical Liaison | Lisa Hugo — base salary (Year 1 launch, full year, $95K midpoint of $85K–$110K) | 95,000 | 97,850 | 100,786 |
| Superannuation (11.5%) | Community & Medical Liaison super | 10,925 | 11,253 | 11,590 |
| Client Case Officer (merged Intake + Case Mgmt) | Year 1 hire from Q2 — combined cradle-to-grave role at $72,000 FTE | 54,000 | 72,000 | 74,160 |
| Superannuation (11.5%) | Client Case Officer super | 6,210 | 8,280 | 8,528 |
| Compliance Officer (0.6 FTE) NEW | Year 2 part-time hire — $80K FTE × 0.6 = $48K (rises to 0.8 FTE in Y3 once LWD's own ACL is granted) | 0 | 48,000 | 65,920 |
| Superannuation (11.5%) | Compliance Officer super | 0 | 5,520 | 7,581 |
| Workers Compensation Insurance | Estimated at 1.5% of total payroll (all employees) | 4,710 | 5,817 | 6,239 |
| Annual Leave Loading (17.5%) | On 4 weeks leave for all employees (CEO + Liaison + Case Officer + Compliance Y2+) | 4,227 | 5,220 | 5,599 |
| People Costs Subtotal | 359,047 | 443,434 | 475,583 | |
| Professional Services | ||||
| Technical Negotiator Contract | Credit Mediation Services Pty Ltd - service agreement | 60,000 | 90,000 | 120,000 |
| Bookkeeper / Accountant | Quarterly BAS, annual accounts, ACNC compliance | 8,500 | 9,500 | 10,500 |
| Legal Advisor | Constitution, service agreements, annual retainer | 12,000 | 5,000 | 5,000 |
| IT and Systems | Case management software, email, file storage, website | 6,000 | 7,200 | 7,200 |
| Professional Services Subtotal | 86,500 | 111,700 | 142,700 | |
| Governance | ||||
| Board Sitting Fees | $3,000 per director per meeting × 4 meetings p.a. × board size (5 directors Y1–Y2, 7 directors Y3+). Board-approved policy. Disclosed in ACNC Annual Information Statement. | 60,000 | 60,000 | 84,000 |
| Governance Subtotal | 60,000 | 60,000 | 84,000 | |
| Operations and Overheads | ||||
| Insurance - Public Liability | Minimum $10M public liability cover | 2,800 | 2,900 | 3,000 |
| Insurance - Management Liability | Directors and Officers cover | 3,200 | 3,400 | 3,600 |
| ASIC and ACNC Fees | Annual review, reporting lodgement | 600 | 600 | 600 |
| Communications and Marketing | Digital advertising, referral partner materials, website | 12,000 | 18,000 | 20,000 |
| Travel and Conference | Partner meetings, sector conferences, board travel | 4,000 | 6,000 | 8,000 |
| Printing and Postage | Client correspondence, creditor letters | 1,500 | 2,000 | 2,500 |
| Bank Fees and Payment Processing | Donation processing, transaction fees | 1,800 | 2,500 | 3,500 |
| Staff Training and Development | CPD, sector training, compliance training | 3,000 | 4,500 | 5,000 |
| Miscellaneous / Contingency (~5%) | Unplanned operational costs | 21,300 | 28,700 | 31,400 |
| Operations Subtotal | 50,200 | 68,600 | 77,600 | |
| Total Annual OPEX | 555,747 | 683,734 | 779,883 | |
* Updated for Laurence's revised structure (2026 mark-up): CEO is Laurence Hugo; Lisa Hugo becomes a paid Community & Medical Liaison from Year 1; Intake Coordinator and Case Manager have been merged into a single Client Case Officer (Year 1, from Q2); a part-time Compliance Officer is added from Year 2. CEO salary set at $165,000 (midpoint of Board-approved $150,000–$180,000 range) with 3% annual indexation. Board sitting fees set at $3,000 per director per meeting × 4 meetings per year × board size: 5 directors in Y1–Y2 ($60K), 7 directors in Y3+ ($84K). Year 1 Technical Negotiator contract held at $60,000 (50% of Year 3 rate). All figures exclude GST. Super at 11.5% SG rate.
Revenue Streams
Life Without Debt will not charge clients for services. All revenue is sourced from donations, grants, and in-kind contributions. The revenue model is designed around diversification across six streams to reduce dependence on any single source. The model is structured to cover full OPEX from Year 1 — no founder bootstrap or personal seed funding is assumed or required.
| Revenue Stream | Description and Strategy | Year 1 ($) | Year 2 ($) | Year 3 ($) |
|---|---|---|---|---|
| Room C: Individual Giving | Online donations (one-off and monthly giving via website), tribute gifts, memorial donations. DGR status enables tax-deductible giving. | 100,000 | 250,000 | 550,000 |
| Room A: Philanthropic Grants | Applications to trusts and foundations (Paul Ramsay, Sidney Myer Fund, Ian Potter, Lord Mayor's, Walter & Eliza Hall). Y1 strategy: 6 to 8 applications targeting $25K–$60K each. Requires ACNC registration and DGR status. | 200,000 | 500,000 | 900,000 |
| Room D: Government Grants | State and federal community services funding (DSS, PHN palliative care, Community Grants Hub). Activates from Year 3 once 24 months of audited evidence base is available. 2026 mark-up: Laurence's prior desktop research found no current government grants specifically funding debt-mediation-for-terminal-illness. Room D therefore plans on commissioning rather than open grant rounds — PHN palliative-care contracts, state hospital social-work budget reallocation, and DSS Community Services pilots. The Liaison and CEO will continue scanning grant rounds quarterly; any open round that opens unexpectedly is upside. | 0 | 0 | 250,000 |
| Room B: Corporate Partnerships | Workplace giving programs, corporate donations, sponsored case funding. Target: 2 to 3 corporate partners by end of Year 1. ESG reporting value for partners. | 80,000 | 200,000 | 450,000 |
| In-Kind from CMA | Credit Mediation Australia / Credit Mediation Services Pty Ltd provides Technical Negotiator services at below-market rate in Year 1 as a start-up contribution. Valued at $60,000 (Year 1 contract rate, partially subsidised). Disclosed as in-kind related party contribution in financial statements. | 60,000 | 30,000 | 0 |
| Room E: Bequests & Major Donors | Legacies and major gifts from donors who have been personally touched by terminal illness. Expected to grow as the organisation's profile develops. | 30,000 | 80,000 | 180,000 |
| Room F: Health Sector Partnerships | Hospital network and PHN commissioning fees. Activates from Year 2 after first MOU and 12 months of referral data. | 0 | 50,000 | 100,000 |
| Total Projected Revenue | 470,000 | 1,110,000 | 2,430,000 | |
* Revenue projections align with the canonical 7-Room portfolio in funding-applications.html and the 10-year model in growth-model.html. The model is designed to cover full OPEX (including the Board-approved CEO salary of $165,000 and board sitting fees of $3,000 × 4 meetings × board size) from Year 1 without founder seed funding. Room G (International) activates from Year 5. All figures in AUD excluding GST.
Break-even Analysis and Surplus Model
Revenue: $470,000 vs OPEX: $555,747. Driver: Lisa's $95K Liaison role added in Year 1. To restore Year 1 break-even, either lift Year-1 fundraising by ~$115K (Room A + Room B push), start Lisa at 0.6 FTE, defer Case Officer to Q3, or apply a Year-1-only CMS in-kind contribution. To be decided by Carla and Laurence at the next working session.
Revenue: $1,110,000 vs OPEX: $683,734. Room F (health sector) opens. Reserve fund still reaches 3-month target by year-end despite Compliance Officer hire.
Revenue: $2,430,000 vs OPEX: $779,883. Room D (government) activates on the back of 24 months of audited evidence. Surplus reinvested into case capacity, endowment seeding, and Year 4 hiring.
Surplus Reinvestment Policy
As a Company Limited by Guarantee with PBI status, Life Without Debt is prohibited from distributing surplus to members. Director sitting fees are permitted, are arm's-length, are disclosed in the ACNC AIS, and are paid only for attended board meetings (no fee, no attendance). All operating surpluses (after permitted fees) are reinvested into:
- Case capacity expansion: Hiring additional Client Case Officers and Credit Representatives to serve more clients
- Technical Negotiator contract expansion: Increasing contracted hours with Credit Mediation Services Pty Ltd in Year 1, then transitioning Negotiators in-house in Year 2 as LWD trains and registers staff as Credit Reps under its own ACL
- Reserve fund: Target of 3 months of operating expenses held in reserve (~$139,000 at Year 1 scale; ~$195,000 at Year 3 scale)
- Direct client support fund NEW · per Laurence's notes: A ring-fenced pool used to cover essential living costs for clients where holding a mortgage or car payment for 12/24/36 months isn't possible (e.g. renters whose landlords can't wait). Eligible categories include: rent assistance, utilities, food, basic medical out-of-pockets and prescriptions. Released by the CEO under a Board-approved hardship policy with caps per client and per category, and audited annually.
- Endowment seeding (Room E) — excess-capital sweep: "Excess capital" means undirected surplus that remains after (i) the 3-month reserve is fully topped up, (ii) all open client matters are funded through to resolution, and (iii) the Direct Client Support Fund is at its policy ceiling. From Year 3 onwards, 5–10% of any remaining surplus is swept into the Room E endowment corpus to compound toward the $10M Year 10 target. The Board sets the sweep percentage each year so endowment growth never starves frontline case capacity.
- Geographic expansion: Building referral networks in underserved states and territories
- Research and advocacy: Contributing to evidence on the impact of debt burden on terminal illness and other life-limiting conditions in Australia
Surplus Sensitivity
The Year 1 surplus is modest (+$27,292 — 6.2% above break-even). Key sensitivities and mitigations:
- If Room A (philanthropic) underperforms ($200,000 Y1 target): securing $140,000 or more still covers full OPEX. Mitigation: submit 6 to 8 applications targeting $25K–$60K each so that 4 to 5 succeed.
- If CMA in-kind contribution is valued at full market rate ($120,000 rather than $60,000): the Year 1 surplus increases to approximately $87,000, providing a stronger initial reserve.
- If Room C (individual giving) or Room B (corporate) exceed targets: Year 1 reserve grows, reducing Year 2 and Year 3 risk and accelerating the 3-month reserve fund target ($110,800 at Year 1 scale).
- Minimum viable revenue to cover OPEX: $442,708. The model projects $470,000 — a 6.2% buffer above the break-even threshold.
- CEO salary downside lever: If Year 1 fundraising falls 10% short, the Board may elect to set the CEO salary at the lower end of the approved range ($150,000) rather than midpoint, releasing $15,000 + $1,725 super = $16,725 of additional headroom. This is a Board-controlled, not founder-controlled, lever.
Governance Framework
Board Composition
Minimum 3 directors required at incorporation. Target composition for a mature board:
- Independent Chair (governance or legal background)
- Treasurer (accounting or finance background)
- 1 to 2 independent directors (health, social services, or philanthropy sector)
- Laurence Hugo may serve as a director, with related party conflicts managed by standing disclosure and recusal policy
Board Meetings, Cadence & Sitting Fees
Minimum governance requirements:
- Board meetings: minimum 4 per year (quarterly)
- Sitting fee: $3,000 per director per meeting (Board-approved policy, disclosed in ACNC AIS)
- Annual board cost: 5 directors × 4 meetings × $3,000 = $60,000 (Y1–Y2); 7 directors = $84,000 (Y3+)
- Written minutes for every meeting, retained for 7 years
- Annual General Meeting (AGM) required under the Corporations Act
- Financial statements presented at AGM
- Board papers circulated minimum 5 business days before each meeting
Conflicts of Interest
Key conflict requiring active management:
- Laurence Hugo is a director of Credit Mediation Services Pty Ltd, which holds ACL 387398 and provides contracted services to the charity
- This is a related party transaction under ACNC Standard 5
- Management: written conflict register, annual disclosure, recusal from Board votes on the service agreement, arm's length pricing, disclosed in Annual Information Statement
- Service agreement to be reviewed and approved by independent board members only
Reporting Obligations
- ACNC Annual Information Statement: lodged annually, publicly available on ACNC Register
- ASIC Annual Company Statement: lodged on anniversary of incorporation
- ATO: income tax return (or exemption confirmation) annually
- Financial audit required when revenue exceeds $1,000,000
- Financial review (lower threshold) when revenue exceeds $500,000
- ACNC financial report: required when revenue exceeds $500,000 (Medium charity)
Regulatory Licencing
- The charity itself does not hold a credit licence - it refers cases to and engages Credit Mediation Services Pty Ltd under ACL No. 387398
- Laurence Hugo must maintain all ACL compliance obligations as the responsible manager under ACL 387398
- The service agreement must clearly delineate that all licensed activities are performed by Credit Mediation Services Pty Ltd, not by the charity or its employees
- ASIC: ACL 387398 annual lodgement of compliance certificate required
Privacy and Data Protection
- Subject to the Privacy Act 1988 (Cth) and Australian Privacy Principles (APPs)
- Must maintain a Privacy Policy (published on website)
- Client data (including medical information) is sensitive information under the APPs - requires explicit consent to collect
- Data breach response plan required (mandatory under Notifiable Data Breaches scheme)
- Donor data management must comply with APP 3 (collection) and APP 6 (use and disclosure)
ACNC Governance Standards - Compliance Checklist
- Standard 1: Purposes and not-for-profit nature documented in Constitution
- Standard 2: Annual Information Statement lodged on time
- Standard 3: Financial management and controls in place
- Standard 4: Suitability of responsible persons (no disqualified persons)
- Standard 5: Duties of responsible persons (including conflicts of interest policy)
- Standard 6: Membership rights protected (CLG member register maintained)
- Standards 7 to 9: Apply to Basic Religious Charities only - not applicable
Year 2 Licensing & Compliance Roadmap NEW · 2026 mark-up
From day one, Life Without Debt operates under Australian Credit Licence No. 387398, held by Credit Mediation Services Pty Ltd (CMS). This is a deliberate Year 1 design: it lets the charity start mediating immediately under a known, audited licence without waiting 6–12 months for its own ACL. Year 2 is the planned transition to LWD's own licence.
| Quarter | Milestone | Owner |
|---|---|---|
| Year 1 — Operating under CMS ACL No. 387398 | ||
| Y1 Q1 | Stand up the Authorised Credit Representative register inside CMS. Appoint the Client Case Officer as a Credit Representative under ACL 387398. AFCA membership confirmed (already in place via CMS). | CEO + CMS |
| Y1 Q2 | Roll out an NCCP training schedule for all staff acting in regulated roles — induction, annual refresher, RG 205 update, hardship-protocol training. Stored as the LWD Compliance Manual v1. | CEO (interim Compliance Lead) |
| Y1 Q3 | Engage an ACL application consultant. Begin drafting LWD's own ACL workbook: Responsible Managers (RMs), Key Person policies, IDR/EDR procedures, RG 205 compliance plan, financial-resources schedule. | CEO + external ACL consultant |
| Y1 Q4 | Board approves the LWD-ACL business case, the Compliance Manual v2 and the Year 2 budget line for the Compliance Officer. Begin RM nominations (Laurence Hugo as lead RM; second RM to be identified). | Board |
| Year 2 — LWD applies for its own ACL | ||
| Y2 Q1 | Hire part-time Compliance Officer (0.6 FTE). Lodge LWD's ACL application with ASIC. Submit RM credentials, financial-resources schedule, IDR/EDR documentation, professional-indemnity insurance. | CEO + Compliance Officer |
| Y2 Q2 | Respond to ASIC RFI cycles. Operations continue under CMS ACL 387398 with zero client impact during the application window. | Compliance Officer |
| Y2 Q3 | Anticipated ACL grant. Transition Credit Reps from CMS register to LWD register. Update client engagement documentation, website, AFCA notification. | Compliance Officer + CEO |
| Y2 Q4 | First full quarter operating under LWD's own ACL. CMS licence remains in place as a fall-back. Compliance Officer steps up to 0.8 FTE in Year 3. | Compliance Officer |
NCCP & ACNC training schedule (all staff)
All staff acting in regulated roles (CEO, Negotiator, Case Officers, Credit Reps) complete the following each year:
- Induction (within first 30 days): NCCP overview, responsible-lending framework, hardship obligations, IDR/EDR, conflicts of interest, AFCA process.
- Quarterly micro-training (~1 hour): Targeted modules — current ASIC focus areas, recent AFCA determinations relevant to debt mediation, ATO hardship updates.
- Annual refresher (1 day): Full Compliance Manual review, ACL conditions, ACNC Governance Standards 1–5, conflict and gifts registers.
- Board-level training: ACNC responsible-person obligations, conflicts policy, Risk & Audit sub-committee briefing.
Programmatic Expansion NEW · 2026 mark-up
The original proposal centres on people with terminal illness and "Sexually Transmitted Debt" (STD) within that cohort. The 2026 mark-up keeps that as the founding focus while formally opening two adjacent expansion fronts so that any surplus funding has a defined, board-approved place to go.
Broader medical-condition pathways
The top causes of death and long-term medical hardship in Australia all create the same debt-and-grief dynamic that LWD was built for. Lisa Hugo's Community & Medical Liaison role explicitly targets these networks:
- Dementia — Dementia Australia
- Heart disease — Heart Foundation
- Lung cancer — Lung Foundation Australia
- Colorectal cancer — Cancer Council, Bowel Cancer Aust.
- Diabetes mellitus — Diabetes Australia
- Pancreatic cancer — Pankind / PanCare
- Prostate cancer — PCFA
- Kidney disease — Kidney Health Australia
- Breast cancer — BCNA, NBCF
- Blood & lymphatic cancers — Leukaemia Foundation
- Liver disease — Liver Foundation
- Ovarian cancer — Ovarian Cancer Australia
- Multiple sclerosis — MS Australia
- Parkinson's disease — Parkinson's Australia
- Motor neurone disease — MND Australia
- Chronic respiratory disease — Lung Foundation Australia
Co-funding hypothesis: peak bodies in each condition currently spend a portion of their support-services budget on financial-stress referrals and small hardship grants. A co-branded referral pathway with LWD lets the peak body redirect that spend into LWD where the saving-per-dollar is materially higher. Laurence's example: "The Cancer Council could cut its financial support budget in half by supporting LWD." Each peak body relationship is treated as a Room F (Health Sector Partnership) opportunity in the revenue model.
Direct Client Support Fund — rent, utilities, food, mortgage / car holds
For clients where holding a mortgage or car payment for 12 / 24 / 36 months is the right intervention, LWD will negotiate that hold directly with the lender. For renters (the majority of our likely cohort) landlords typically cannot offer that runway. LWD will therefore maintain a board-controlled Direct Client Support Fund that can release short-term support for:
- Rent: up to 3 months bridging where eviction is the alternative
- Utilities: electricity, gas, water — pay-direct to retailers; disconnection prevention
- Food & essentials: in partnership with Foodbank / OzHarvest where available
- Medical out-of-pockets: co-payments, prescriptions, equipment hire — for the index illness
- Mortgage / car payment holds: via formal hardship arrangements with the lender (negotiated by the Credit Rep, paid by the client / lender under the deferred plan — not paid by LWD)
Policy guardrails: per-client cap, per-category cap, board-approved hardship rubric, annual external audit. Funded from surplus and a dedicated Room B sub-stream "Client Support Endowment". Sized to match expected client volumes — see the Year 4+ growth model for projection.
"Sponsor a Family" major-donor program — short private video testimonials
Borrowed from the child-sponsorship model that has worked for international aid charities for decades. With clients' explicit written consent, the Communications Officer captures a short video clip (1–2 minutes) in which the client reflects on their experience with LWD — what was happening before, what we resolved, what changed. The clip is strictly private, not for public release. It is shared only with major sponsors / donors who have signed a confidentiality undertaking, paired with an LWD-prepared narrative cover (case overview, debt resolved, creditors negotiated, anonymised where the client prefers).
- Consent first, always: opt-in only, written consent specifying which sponsor tiers may view, time-limited (5 years default), withdrawable at any time, full pseudonymisation option available, no clip released until the case is closed.
- Sponsorship tiers: mapped to Room B (Major Donors) and Room E (Bequests). A clip is shared per donor per year at the relevant tier.
- Privacy and security: hosted on a secure portal with single-link expiry, watermarked per donor, never downloadable, governed by the LWD Privacy Policy and the new Client Storytelling Policy.
- Why it works: creates a felt, human connection between donor and outcome — the same emotional engine that made child sponsorship the most durable retention model in the sector — without compromising client dignity or privacy.