CDR Sectoral Assessment for the Open Finance Sector – Non Bank Lending

This document outlines feedback on the Code Governance Committee’s priorities for monitoring compliance with the General Insurance Code of Practice. We appreciate the CGC’s focus on key issues impacting consumers and financial counsellors. We outline several recommendations to improve insurance outcomes for consumers.

This joint submission provides feedback on the Australian Securities and Investment Commission’s draft regulatory guide for low cost credit contracts. Our organisations have been advocating for the regulation of BNPL products for years and keenly await the implementation of the new legislative regime, which will reduce the risk of people being signed up to unaffordable BNPL debts that leave them worse off. However, the regime is novel and complex so we strongly support ASIC’s intention to provide guidance on the laws.