Lenders and brokers are being caught out by the very broad definitions of credit services and intermediaries that apply under the National Consumer Credit Protection Act. Gadens Lawyers' partner, Vicki Grey, said yesterday that brokers and aggregators had run into trouble with the new regime, which has been in force since July last year, because they have not recognised the extent of its coverage. Grey said: "If a licensee (a broker or aggregator) appoints a company as a credit representative it also needs to appoint the individuals who will be acting in that capacity. "And, because the law defines credit services very broadly, there are more levels that need licensing or appointment as credit representatives. "Basically, you have to appoint everyone in the chain. We have been coming across some groups that have not done that." Gadens Lawyers' partner, Jon Denovan, said another area that was causing a lot of confusion was the scope of authority for credit representatives. Denovan said: "It has surprised some aggregators to learn that there is no joint appointment. A credit representative is appointed to introduce deals to an aggregator's panel of lenders." Credit representatives can only deal with other parties, such as another broker or aggregator, if their licensee agrees to it. Licensees may be reluctant to give such agreement because they are liable for the actions of their credit representatives.