Credit Card Responsible Lending Assessments – Joint Submission
Submission to: Australian Securities Investments Commissions
Related Projects
Review of the Privacy Act
Submission to: Attorney General’s Department
Joint submission from Financial Rights and FCA (Financial Rights as the lead author) responding to an October 2021 discussion paper from the Attorney-General’s Department considering the scope of the Privacy Act and if its enforcement mechanisms remain fit for purpose. The submission supports proposed amendments to the definition of personal information. The submission argues that the exemption for small businesses from the Privacy Act should be removed including that the Act apply to the new category of “trusted advisors” for the purposes of the consumer data right. (Financial counsellors are trusted advisors.) The submission also argues for the consent provisions to be strengthened, that pro-privacy default settings be enabled by default and that there should be a right to erasure. Complaints handling should be undertaken by the creation of a new body, a Federal Privacy Ombudsman.
Joint submission from Financial Rights and FCA (Financial Rights as the lead author) responding to an October 2021 discussion paper from the Attorney-General’s Department considering the scope of the Privacy Act and if its enforcement mechanisms remain fit for purpose. The submission supports proposed amendments to the definition of personal information. The submission argues that the exemption for small businesses from the Privacy Act should be removed including that the Act apply to the new category of “trusted advisors” for the purposes of the consumer data right. (Financial counsellors are trusted advisors.) The submission also argues for the consent provisions to be strengthened, that pro-privacy default settings be enabled by default and that there should be a right to erasure. Complaints handling should be undertaken by the creation of a new body, a Federal Privacy Ombudsman.
Response to the “Personal Insolvency Discussion Paper”
Submission to: Attorney-General’s Department
Joint consumer submission (Ied by Financial Rights Legal Centre) in response to the above discussion paper, which in turn came from a Roundtable hosted by the Attorney-General in March 2023. We argue that the forced bankruptcy threshold should increase from $10,000 to $50,000, that the bankruptcy notice period be extended to 60 days, that the National Personal Insolvency Index be modernised and harmonised with the credit reporting framework, that entering a debt agreement should not be an act of bankruptcy and that the payment to income ratio for a debt agreement should be set by legislative instrument to mitigate against people entering into unaffordable agreements.
Joint consumer submission (Ied by Financial Rights Legal Centre) in response to the above discussion paper, which in turn came from a Roundtable hosted by the Attorney-General in March 2023. We argue that the forced bankruptcy threshold should increase from $10,000 to $50,000, that the bankruptcy notice period be extended to 60 days, that the National Personal Insolvency Index be modernised and harmonised with the credit reporting framework, that entering a debt agreement should not be an act of bankruptcy and that the payment to income ratio for a debt agreement should be set by legislative instrument to mitigate against people entering into unaffordable agreements.