Pre-Budget Submission re 2020-21 Budget
Submission to: Treasury
Related Projects
Australian Banking Association Application for ACCC Authorisation re Financial Relief Programs April 2020
Submission to: ACCC
Joint consumer group submission (led by the Consumers Federation of Australia) in response to an application by the Australian Banking Association and its member banks, for authorisation by the ACCC for banks to agree on the minimum standards for consumer financial relief programs and to promote customers’ access to banking services in an environment where social distancing is in place. We support both of these applications. In relation to financial relief we suggest that the ACCC’s final authorisation require that banks consult with consumer groups about their content and that there be public reporting about the outcomes of these programs.
Joint consumer group submission (led by the Consumers Federation of Australia) in response to an application by the Australian Banking Association and its member banks, for authorisation by the ACCC for banks to agree on the minimum standards for consumer financial relief programs and to promote customers’ access to banking services in an environment where social distancing is in place. We support both of these applications. In relation to financial relief we suggest that the ACCC’s final authorisation require that banks consult with consumer groups about their content and that there be public reporting about the outcomes of these programs.
Rationalisation of Ending ASIC Instrument Measures
Submission to: Treasury
Joint submission from the financial counselling sector in response to proposals to move the current licensing exemptions applying to financial counselling agencies from ASIC legislative instruments into the primary law and regulations. The current licensing exemptions exempt financial counselling agencies from having to hold an Australian Financial Services Licence or an Australian Credit Licence, as long as the agency meets certain requirements. We support the policy intent of the proposed rationalisation, but recommend that the wording in the current ASIC instruments is replicated exactly in the new regulations, rather than introducing new terms. The submission also supports the proposal that rural financial counselling agencies are provided with an AFSL exemption.
Joint submission from the financial counselling sector in response to proposals to move the current licensing exemptions applying to financial counselling agencies from ASIC legislative instruments into the primary law and regulations. The current licensing exemptions exempt financial counselling agencies from having to hold an Australian Financial Services Licence or an Australian Credit Licence, as long as the agency meets certain requirements. We support the policy intent of the proposed rationalisation, but recommend that the wording in the current ASIC instruments is replicated exactly in the new regulations, rather than introducing new terms. The submission also supports the proposal that rural financial counselling agencies are provided with an AFSL exemption.