Credit Card Responsible Lending Assessments – Joint Submission

Submission to: Treasury (Financial Services Reform Taskforce)
This package of draft legislation is a direct response to the Financial Services Royal Commission. The draft bills remove the current exemptions for funeral expenses policies from the licensing and conduct regime in the Corporations Act. We also argue that other exemptions for funeral insurance should also be removed from the Life Insurance Act and the Insurance Contracts Act. The submission supports the commencement date of 1 April 2020. The submission also raises concerns about the impact on Aboriginal and Torres Strait policy holders of funeral insurance company ABCF. If this company does not obtain a licence under the new regime, a compensation/redress scheme will be needed for these policy holders. They should not face the loss of past contributions and no future coverage for the costs of their funerals, because of a past legal loopholes and poor drafting.