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.
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.
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 1 — ASIC Company Registration
Formation of Life Without Debt Ltd as a public company limited by guarantee under s.117 of the Corporations Act 2001 (Cth). This is the entry point — every downstream registration depends on the ACN issued at this stage.
CLG Constitution
35-clause charity-compliant constitution with paramount charitable-purpose, not-for-profit, DGR-compliant winding-up, and precedence clauses.
Form 201 Content Brief
Field-by-field content for ASIC Form 201 (Application for Registration as an Australian Company).
Consent to Act Forms
Five statutory consents: Director (s.201D), Secretary (s.204C), Application for Member + Guarantee, Consent to Occupation of Registered Office, ACNC Responsible Person Declaration.
First Directors' Resolutions
16 resolutions passed immediately after ACN issue: adoption of Constitution, appointment of Chair/Secretary/CEO, executive remuneration (with recusals), CoSai in-kind engagement, banking, insurance, delegations, and ACNC application lodgement authority.
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.
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.
Board Charter
Attachment C — role of the Board, composition, meeting protocols, decision authorities, committees (Audit & Risk, Nominations & Remuneration, Case Review).
Conflicts of Interest Policy
Attachment D — Policy + Register template. Names the three standing conflicts already identified: Laurence Hugo, Lisa Hugo (spouse), Carla Oliver (CoSai).
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).
Reserves & Financial Sustainability Policy
Attachment F — 3-month operating reserve target, 40% max funding-source concentration, solvency review triggers.
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.
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.
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).
Package 4 — Australian Credit Licence (Year 2)
Application for an Australian Credit Licence under s.29 of the National Consumer Credit Protection Act 2009 (Cth), authorising the Company to provide credit assistance and to act as an intermediary for hardship variations of consumer credit contracts on behalf of its beneficiaries. Deferred to Year 2 to allow evidence of competent operation, adequate resources, functioning IDR, and Responsible Manager experience to be built up.
Form CL01 Content Brief
Field-by-field content for ASIC Form CL01. Categories of credit activity sought, Responsible Manager evidence, fit-and-proper checks, financial resources, AFCA and PI insurance.
Credit Licence Compliance Plan
Annexure C to Form CL01. RG 205-aligned mapping of each general conduct obligation in s.47(1) NCCP Act to controls, evidence and monitoring. Includes IDR/AFCA, training, vulnerable-consumer protections, breach reporting, and interaction with ACNC obligations.
ACL 387398 — wording review
Every mention of ACL 387398 and the Credit Licence across the site, grouped by exact wording pattern. Use this to review current formulations and decide the wording changes for consistent site-wide application.
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.
Constitutional Design
The reasoning behind every clause of the Constitution — twelve design decisions, every option considered, every pitfall identified, every mitigation adopted, and the full text of every applicable statute, regulation, code and case. Written for a non-lawyer director to be able to interrogate any clause and follow the chain of reasoning to its source.
Constitutional Design Paper
4 parts: (I) foundations + glossary, (II) 12 design decisions with options / pitfalls / mitigations / chosen path, (III) legislative sourcebook with ~25 sources quoted verbatim + plain-English + LWD application, (IV) clause-by-clause traceability matrix.
Constitution v1 (draft)
The 35-clause filing-grade Constitution itself. Clause-N anchors from the Design Paper land directly on the corresponding existing clause. To be reviewed by a charity-law specialist solicitor before ASIC lodgement.
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.
Solicitor Review Pack
Phase-by-phase review index across all 20+ documents · engagement letter template · briefing note · detailed sign-off checklist by document · printable tick-box manifest with 20-item completion register.
First Board Meeting Pack
Full agenda (20 items) · Chair's script for statutory duties briefing, standing conflicts, and related-party resolutions · move-and-second templates for all 12 resolutions · minutes template with pre-drafted narrative · attendance register · post-meeting checklist for the Secretary.
Lodgement-Ready Companions
The "clean" companions to the annotated ASIC and ACNC drafts. Same content, no commentary — designed to be printed and handed to the lodging agent, or pasted field-by-field into the ACNC's online portal.
ASIC Form 201 Pre-Fill Worksheet
Single-sheet worksheet — every field of Form 201 pre-populated, blanks where the promoter must confirm, pre-lodgement checklist, post-lodgement action list. Print and hand to the registered ASIC agent.
ACNC Portal-Ready Answers
Field-by-field answers grouped by ACNC portal step (11 steps). Distilled from the annotated ACNC application; no rationale, no footnotes — only the text to paste at charity.acnc.gov.au.
Board Formation & Governance Registers
The documents that get the Board built and its statutory registers opened. The Director Recruitment Brief is used to fill the independent seats; the Board Charter (now with a full Delegated Authorities Schedule) is adopted at the first meeting; the Register of Interests is opened by the Secretary at the same meeting.
Independent Director Recruitment Brief
Role description · independence test · 8-domain skills matrix · candidate profile · approach-letter template · nomination form · shortlist evaluation rubric · recruitment timeline.
Board Charter (build-out v2)
Now with a full 9-part Delegated Authorities Schedule (§5.1 strategy · §5.2 governance/risk · §5.3 financial · §5.4 beneficiary services · §5.5 people · §5.6 related parties · §5.7 banking · §5.8 fundraising/comms · §5.9 data/privacy) and a three-committee sub-committee structure (A&R, N&R, Beneficiary Services).
Register of Interests
Statutory register under ss.191–192 Corporations Act. Template + three pre-filled standing declarations for the known interested parties (Laurence Hugo, Carla Oliver via CoSai, expected Chair). Includes case-by-case disclosure log and review cadence.
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.
Founding-Donor One-Pager
The single-sheet leave-behind. Hero panel · three headline stats · four activity pillars (hardship negotiation · direct relief · direct debt payoff · advocacy) · "how your gift is used" allocation table · three-tier ask ($25k Founding Circle / $100k Founding Patron / $500k+ Lead Founding Partner) · governance checklist.
Founding-Donor Deck (10 slides)
The meeting deck. Title · problem · scale · what we do · how a case works · how money is spent · governance · team · the ask · next step. Renders one slide per A4-landscape page when printed to PDF (custom @page landscape rules).
Case Studies Bank (3 composites)
Three end-to-end illustrative cases (heavily disclaimed as composites): "Margaret" 62, pancreatic cancer, regional NSW; "David" 48, MND, Melbourne; "Kwame" 71, prostate cancer, Adelaide (post-mortem / secondary-beneficiary path). Each case: situation → 4-step case flow → intervention detail → summary with authorities engaged. Will be replaced with consent-based real cases once operating.
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.
Compliance Calendar Y1–Y3
Quarter-by-quarter timeline from incorporation to end of Y3 — every ASIC / ACNC / ATO / state-fundraising / insurance / sub-committee event on one page, with a per-obligation reference index and state-by-state fundraising authority table.
Privacy & Beneficiary Data Handling Policy
Comprehensive APP-compliant privacy policy tuned for the highest-sensitivity data (SIS Reg 6.01A certificates, hardship data, deceased-estate handling). Includes six information-category schedule, retention schedule, data-breach response plan, and full APP 1–13 compliance map.
Beneficiary Intake Pack
Six-step operational intake (welcome · identity · health · consents · hardship · needs assessment · case-opening decision) that operationalises the Privacy Policy consents and the Direct Relief Policy assessment. Includes five explicit consent blocks and a duty-of-care escalation protocol.
Risk Register — Y1 populated
27 identified Y1 risks across 7 categories (Strategic · Regulatory · Financial · Operational · Data · Safeguarding · Reputational), each rated on a 5×5 matrix with controls, residual rating, owner, and treatment plan. Explicitly identifies R-SFG-01 as a Board-accepted residual above appetite with reasons.
Public-Facing & Comms Materials
The externally-facing communications layer — the copy source that will feed the public LWD website rewrite once ACNC / DGR endorsement is confirmed, and the single-source-of-truth media kit that governs everything LWD says externally. Both documents were audited alongside the operating policies (Direct Relief, Privacy, Intake) so the public-voice and staff-voice stay locked together.
How LWD Can Help — four beneficiary-facing draft pages
Plain-English copy for four audiences: 1) the person with a diagnosis · 2) a family member or carer · 3) an executor of a deceased-beneficiary estate · 4) a health professional / financial counsellor / lawyer wanting to refer someone. Each page ends with the same three things (what happens next · what does not happen · next step). Reading age ~Y8, warm and direct, never promising a specific outcome. Includes editorial-governance table mapping every claim back to its Board-approved anchor policy.
Media Kit & Boilerplate
Approved boilerplates (25 / 50 / 100 / 200 words) · full factsheet · quote library (CEO · CFO · Chair) · terminology guide (say / don't say) · media-request handling protocol · visual identity placeholders · photography rule. Nothing goes out under the LWD name that is not in this kit, and any deviation is a Board Charter DAS §5.8 decision.
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 category | Lawful for LWD? | Conditions |
|---|---|---|
| CEO and staff salaries (arm's length) | Yes | Reasonable, benchmarked, Board-approved, in furtherance of charitable purpose (ACNC Remunerating Responsible People). |
| Executive Director remuneration (Laurence Hugo) | Yes | Constitution permits (clause 8/23), reasonable and benchmarked, related-party approval by non-conflicted Directors, disclosed under AASB 124. |
| Employment of related party (Lisa Hugo) | Yes | Merit-based selection, benchmarked pay, Laurence Hugo recused, disclosed under AASB 124. |
| Professional-service fees to a related entity (CoSai) | Yes, subject to conditions | Year 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 costs | Yes | Means-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 expenses | Yes | Same 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) | Yes | Only 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) | Yes | Standard 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 campaigns | Yes, if ancillary | Constitution 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 relief | No | Prohibited by Direct Relief Policy and by PBI "public class" requirement (ACNC PBI Interpretation Statement §11–17). |
| Distribution of surplus to Members | No | Prohibited by Constitution clause 7 (not-for-profit) and clause 33 (winding-up). |