This submission is based on the casework experiences of Small Business Debt Helpline financial counsellors. We welcome the development by AFCA of an approach document. Our submission argues that the approach document needs to explicitly consider the issue of customers in vulnerable circumstances, that there is a need for clear guidance about what constitutes “reasonable inquiries” in assessing a business purpose and emphasises the importance of assessing the type of financial firm, type of credit provided and characteristics of the borrower for all amounts of credit, including small amounts. In the experience of the Helpline, small amounts of credit can snowball and put personal assets, including the family home at risk.
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