PPSR Housekeeping A 12-step checklist for reviewing & updating your registrations

Keeping on top of your registrations on the Personal Property Securities Register (PPSR) isn’t just a one-time task – it’s an ongoing commitment to safeguarding your interests. 

The PPSR is important for businesses that hire, lease, finance, sell goods on credit or extend credit to customers. It’s there to protect your business so you can recover property rightfully belonging to you or get paid in case of a customer insolvency.

Since the 2012 introduction of the Personal Property Securities Act (PPSA), you need a correctly registered security interest to protect goods that you have an interest in. Even a minor error during PPS registration can invalidate your security interests. For example, an unnoticed mistake made when identifying the grantor might render your claim worthless when attempting to recover goods from an insolvent customer.

Beyond registration errors, changes in customer details pose risks if they go unnoticed and are not corrected. Often, customers fail to communicate changes like a new trading entity, placing the responsibility on your business to monitor and update accordingly. 

Here’s a 12-step checklist for how to keep your registrations updated. 

Step 1: Match and register accounts

Check that all current accounts (or accounts within your “selection criteria”) are registered.

• Match the PPSR registrations to your debtors listing.

• Register missing accounts.

• If any accounts are no longer active and have no outstanding balance, consider discharging the registration.

Step 2: Check the grantors match the customer records

• Check grantors are correctly described. The PPSR regulations are very specific depending on the entity type and available identifiers.

The following table is simplified but should suffice for the majority of cases: 

There are special requirements for other entities such as trustees, registered schemes, foreign companies, clubs, charities, associations, and unincorporated entities. 

Step 3: Validate ACNs and ABNs

Confirm ABNs are still active and ACNs registered. Entities might undergo changes such as cancelling their ABN, deregistering their ACN, or entering some form of administration.

Step 4: Ensure accurate asset description

Check that assets are correctly described (if applicable).

The rules for describing serial numbered goods are very specific. For example, Motor Vehicles are described in the following order:

• VIN, and if there is no VIN,

• chassis number, and if no VIN or chassis number,

• manufacturers number.
   

Step 5: Check Secured Party Group (SPG)

• Review SPGs to see if there have been business changes like mergers, acquisitions, or divestments. A new SPG may be required.

• If you have multiple SPGs, consider whether one consolidated SPG would be more efficient.

Step 6: Review internal hire or lease agreements

• Where applicable, update the internal Business Hire Agreement or Operating Lease.

• Update the asset listing and ensure serial numbered assets are registered.

Step 7: Check that registration details are correct

• Review the accuracy of the checkboxes filled out during registration, including collateral type, class, and description.

• Ensure you have responded to all the questions about whether proceeds are claimed and provided a description. Ensure proper completion of checkboxes for inventory, subject to control, subordinate and PMSI.

• For serial numbered goods, check the serial number, number type, vehicle registration number and descriptive text.

Step 8: Renew expiring registrations

• Registrations must be renewed prior to expiry. 

• Identify registrations set to expire this year by checking their expiration dates.

• Check that customer details are still valid.

• Detect and rectify any anomalies that might invalidate a registration.

• Consider whether transitional registrations are still required.

• Allow registrations on closed accounts to expire.

Step 9: Document your PPS policy

Develop a comprehensive policy governing registry management procedures so that your PPS procedures are consistent and not dependent on the knowledge of just one team member. This should include:

• new registrations

• amendments 

• renewals

• discharges 

• reporting

• checking and housekeeping. 

Step 10: Review registrations against your business

A clean register is important when raising finance or selling a business or certain assets.

• Search the PPSR for registrations placed by other entities on your business.

• Reach out to the secured party to clarify any uncertainties or discrepancies about specific registrations.

• Request discharges for registrations that aren’t necessary or have no security interest.

Step 11: Extend coverage to New Zealand

• Register on New Zealand’s PPSR when dealing with customers there. The NZ register is similar but not the same as the Australian PPSR.

Step 12: Maintain system security

• Manage access to your PPSR platform, safeguarding user access, SPG access codes and registration tokens to prevent unauthorised access and malicious activities.

Additional considerations for PPS Compliance

Regularly revisiting and updating these checkpoints helps ensure accurate registrations and shields your business from potential risks. Remember, each business is unique, and not all items on this checklist may apply universally. Additional considerations may include whether you have a registrable security interest, the timing of registrations, the need to send verification statements, and your PPS strategy/policy. 

In case of a customer insolvency, vigilance with PPS registration and maintenance processes will protect your position as a secured creditor. It’s important to know your rights and act quickly. The insolvency practitioner is not there to just look after your interest. Their role is to look after all the business’s creditors. Seek professional advice from a PPSR expert when required. 

For purpose-fit guidance and exceptional support in benefiting from the PPSR, contact EDX by Equifax. We assist with everything from the advisory and initial set-up to bulk processing and ongoing registration management with alternate solutions for different business requirements. 

EDX is a subsidiary of Equifax established to help businesses take the complexity out of the PPSR. Our team comprises PPSR veterans with long-standing expertise in registering security interests, insolvency and credit management in Australia and New Zealand.  

Detect compliance issues with our Assurance Review and register your security interests seamlessly with our purpose-built software solution. Learn more at https://www.edxppsr.com.au/

Disclaimer: This article covers general matters. The PPS Act is complex. There may be circumstances where other considerations apply. We recommend obtaining advice and support from PPSR experts.