All packages · Draft review
ASIC · ACNC · ATO DGR · ACL

Registrations Hub

All four draft registration packages for Life Without Debt Ltd, ordered by lodgement sequence. Each document is a filing-grade draft prepared to the standard expected by the relevant regulator, with items requiring Board/legal confirmation clearly marked in orange.

DRAFT · For internal review · Not for lodgement without charity-specialist legal review
Required legal review before lodgement

These drafts have been prepared based on published ACNC, ASIC and ATO guidance current at the date of drafting. Before any document is lodged with a regulator, the entire package must be reviewed by an Australian solicitor with charity-law and — for Package 4 — credit-licensing expertise. Placeholders marked [TO CONFIRM] require decisions by Laurence Hugo (as founder) and Carla Oliver (as CoSai principal) that this draft cannot pre-empt.

Recommended sequence

ASIC (Package 1) → ACNC (Package 2) → ATO DGR (Package 3) → (Year 2) ACL (Package 4). See the Registration Roadmap for full dependencies, timings and unlock points.

Package 2 — ACNC Charity Registration

Application to the ACNC for registration as a charity under s.25-5 of the ACNC Act, with the primary subtype of Public Benevolent Institution and the secondary subtype of a charity for the purpose of advancing social or public welfare. Includes the complete governance policy suite that will bind the Board from day one.

ACNC Application Content Pack

11-section application: purposes, activities, beneficiaries, subtype selection, Governance Standards narrative, Responsible Persons, financials, PBI supplementary evidence, declaration.

Charity Portal · ~37 KB

Public Benefit Test Memo

Attachment B — evidence satisfying s.6/s.7 Charities Act 2013 (Cth). Documents application of the s.7 presumption for relief of sickness and poverty.

Attachment B · ~10 KB

Board Charter

Attachment C — role of the Board, composition, meeting protocols, decision authorities, committees (Audit & Risk, Nominations & Remuneration, Case Review).

Attachment C · ~9 KB

Conflicts of Interest Policy

Attachment D — Policy + Register template. Names the three standing conflicts already identified: Laurence Hugo, Lisa Hugo (spouse), Carla Oliver (CoSai).

Attachment D · ~9 KB

Related-Party Transactions Policy

Attachment E — five related-party categories including full CoSai engagement protocol (Year 1 in-kind; Year 2 requires two competitive quotes if paid).

Attachment E · ~10 KB

Reserves & Financial Sustainability Policy

Attachment F — 3-month operating reserve target, 40% max funding-source concentration, solvency review triggers.

Attachment F · ~7 KB

Direct Relief Policy

Attachment G — three relief categories (essential living / unfunded health / debt discharge). Caps: $5k/event, $15k/12mth, 25% aggregate. Means-tested. No related-party payments.

Attachment G · ~11 KB

Policy & Law Reform Advocacy Memo

Constitutional read on whether donations can lawfully fund legislative-reform advocacy work (Prof. Deen Sanders). Clause 4(c) enabling analysis · Aid/Watch v FCT political-purpose bar · three qualifications · 15% advocacy-spend cap proposal · illustrative $38K–$68K first-year envelope.

Governance · Draft Memo v0.1 · ~29 KB

Package 3 — ATO DGR Endorsement (Item 4.1.1)

Application to the ATO for endorsement as a Deductible Gift Recipient under item 4.1.1 of s.30-45 of the Income Tax Assessment Act 1997 (Cth), on the basis that the Company is a Public Benevolent Institution. Contains the dominant-purpose evidence and three-element PBI analysis (public / benevolent / institution) with citation of the ATO Commissioner's Interpretation Statement (29 Sep 2025).

Sequencing & Timing

One-page roadmap showing the four packages in order, with prerequisites, expected regulator turnaround times, dependencies, and unlock points.

Supporting Legal Research

Deep-research memo on Australian legislation and regulatory guidance covering (i) what the law considers "terminal illness", (ii) what creditors must do and what they can lawfully do at their discretion, and (iii) what happens to debts on death. Used as the evidentiary spine for the ACNC "public benefit" and DGR "benevolent relief" arguments.

Solicitor & First Board Meeting

The two operational documents that sit between the drafts and lodgement. The Solicitor Review Pack presents the whole registration package in the order a charity-law specialist would want to review it, with an engagement letter template and a tick-box manifest. The First Board Meeting Pack is the agenda, Chair's script, resolutions, minutes template, and attendance register for the first meeting of Directors immediately after ASIC issues the ACN.

Fundraising & Founding-Donor Materials

The externally-facing pack used to approach founding donors while ASIC / ACNC / DGR lodgement is in flight. The one-pager is the leave-behind; the deck is used in the meeting; the case-studies bank illustrates what a completed LWD case looks like end-to-end. All three carry the same "how your gift is used" allocation (75% direct relief · 15% BLO/staff · 5% governance · ≤5% fundraising) and are consistent with the Direct Relief Policy caps built into the Board Charter's Delegated Authorities Schedule §5.4.

Operating Compliance & Case Management

The operating layer — what LWD actually does day-to-day once it is registered. The Compliance Calendar tells the Secretary and Board what is due and when for three years; the Privacy Policy governs the exceptionally sensitive data that a terminally-ill beneficiary must share to be helped; the Beneficiary Intake Pack is the six-step operational form that opens every case; and the Risk Register is the standing statutory-facing instrument by which Directors discharge their duty of care under Corporations Act s.180(1). All four cross-reference each other and lock into the Board Charter and its Delegated Authorities Schedule.

Items requiring Board / Founder Decisions Before Lodgement

The following items appear as [TO CONFIRM] or [LAURENCE/CARLA TO CONFIRM] throughout the drafts and require decisions from you before lodgement:

  • Company name availability — confirm "Life Without Debt Ltd" is available via ASIC's name check (or select a fall-back name)
  • Directors — final list of at least three Directors, with independent majority (Prof. Sanders confirmed as Chair or alternative independent Chair identified)
  • Company Secretary — appointment (may be a Director; must be Australian-resident)
  • Registered office — physical Australian address with consent-to-occupation signed
  • Initial Members — names of Members signing the Application for Member and $10 Guarantee
  • CEO remuneration — Board-approved total remuneration package for Laurence Hugo, benchmarked against charity-CEO salary surveys
  • Beneficiary Liaison Officer remuneration — Board-approved package for Lisa Hugo, benchmarked against equivalent-role surveys
  • CoSai engagement terms — Year 1 in-kind letter of engagement executed; Year 2 pricing framework agreed subject to competitive-quote requirement
  • Bank and signatories — bank selected, signatories nominated
  • Insurance limits — D&O, public liability, PI, cyber, workers' compensation policy limits confirmed with a broker
  • Financial year end — draft assumes 30 June (standard); confirm or elect an alternative
  • Direct Relief caps — confirm the $5,000 per event, $15,000 per 12 months per beneficiary, and 25% aggregate caps are acceptable

Fund-Use Research Summary (as requested)

The most-asked question — what can a registered charity lawfully pay for, and under what conditions? — is addressed in detail in section 7 of the DGR/PBI Application and in the Direct Relief Policy. In summary:

Payment categoryLawful for LWD?Conditions
CEO and staff salaries (arm's length)YesReasonable, benchmarked, Board-approved, in furtherance of charitable purpose (ACNC Remunerating Responsible People).
Executive Director remuneration (Laurence Hugo)YesConstitution permits (clause 8/23), reasonable and benchmarked, related-party approval by non-conflicted Directors, disclosed under AASB 124.
Employment of related party (Lisa Hugo)YesMerit-based selection, benchmarked pay, Laurence Hugo recused, disclosed under AASB 124.
Professional-service fees to a related entity (CoSai)Yes, subject to conditionsYear 1 recommended as in-kind. From Year 2 requires competitive quotes, non-conflicted Board approval, AASB 124 disclosure. Never at above-market rates.
Direct relief payments to beneficiaries — essential living costsYesMeans-tested, within Direct Relief Policy caps ($5k/event, $15k/12mth, 25% aggregate), documented, not to related parties (ACNC PBI Interpretation Statement §44).
Direct relief payments — unfunded health/palliative expensesYesSame conditions as above. Framed as "health-related" to avoid the narrow "Health Promotion Charity" DGR category limitations.
Direct debt discharge (paying a beneficiary's creditor)YesOnly after negotiated reduction, only within caps, documented as advancing PBI purpose (relief of financial distress) rather than a private benefit.
Debt-negotiation professionals (external legal / financial-counsellor fees)YesStandard operating expense. Paid at arm's-length rates. Records retained. (Where the professional is a related party, the related-party protocol applies.)
Advocacy and awareness campaignsYes, if ancillaryConstitution clause 4(b) — must remain ancillary to the direct-relief dominant purpose. See Global Citizen vs Equality Australia analysis in DGR application §6.
Payments to Directors, staff or their relatives as beneficiaries of direct reliefNoProhibited by Direct Relief Policy and by PBI "public class" requirement (ACNC PBI Interpretation Statement §11–17).
Distribution of surplus to MembersNoProhibited by Constitution clause 7 (not-for-profit) and clause 33 (winding-up).
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