FCA submissions to government, regulators and others.
August 2019
Submission to: ASIC
We have welcomed ASIC’s decision to review its guidance on internal dispute resolution for financial services providers. We support making the guidance on internal dispute resolution enforceable. We recommended that fairness and good industry practice are considered when financial firms are responding to complaints. We also supported a 30 day time limit to respond to a complaint.
We have welcomed ASIC’s decision to review its guidance on internal dispute resolution for financial services providers. We support making the guidance on internal dispute resolution enforceable. We recommended that fairness and good industry practice are considered when financial firms are responding to complaints. We also supported a 30 day time limit to respond to a complaint.
August 2019
Submission to: ASIC
We support the approach by ASIC on the implementation of the product intervention power. In legislating this power, the Parliament has recognised the need for ASIC to prevent or halt significant consumer detriment when it is identified.
We support the approach by ASIC on the implementation of the product intervention power. In legislating this power, the Parliament has recognised the need for ASIC to prevent or halt significant consumer detriment when it is identified.
July 2019
Submission to: ASIC
We support ASIC using its product intervention power to prohibit short term lending models (the Cigno model). The short term lending model currently being used by Cigno causes significant harm to people and we urge ASIC to intervene urgently.
We support ASIC using its product intervention power to prohibit short term lending models (the Cigno model). The short term lending model currently being used by Cigno causes significant harm to people and we urge ASIC to intervene urgently.
July 2019
Submission to: Australian Financial Complaints Authority (AFCA)
June 2019
Submission to: Australian Banking Association
Submission calls for the Banking Code of Practice to include among other changes: further principles and specific provisions to better protect vulnerable people; to more imaginatively set out critical information that people need to know instead of relying on the “fine print”; training for staff to help them ask direct questions about relevant personal characteristics that leave a person more vulnerable; and providing actual access in remote areas, such as pop-up banking.
Submission calls for the Banking Code of Practice to include among other changes: further principles and specific provisions to better protect vulnerable people; to more imaginatively set out critical information that people need to know instead of relying on the “fine print”; training for staff to help them ask direct questions about relevant personal characteristics that leave a person more vulnerable; and providing actual access in remote areas, such as pop-up banking.
June 2019
Submission to: Department of Agriculture
Submission calls for the RFC Service to work much more closely with generalist financial counselling services because of the many similarities in the work of both roles. Possible benefits include better communication and professional development and ultimately better client outcomes.
Submission calls for the RFC Service to work much more closely with generalist financial counselling services because of the many similarities in the work of both roles. Possible benefits include better communication and professional development and ultimately better client outcomes.
May 2019
Submission to: Australian Securities and Investments Commission
Submission calls for AFCA to make it explicit that RG209 will be a relevant factor in resolving disputes about responsible lending; that compliance with RG209 should be a key commitment in industry codes that deal with lending under the National Credit Act; that the required inquiry and verification steps be set out in RG209; that these required steps not be reduced for any credit products; and that credit providers should be audited regularly.
Submission calls for AFCA to make it explicit that RG209 will be a relevant factor in resolving disputes about responsible lending; that compliance with RG209 should be a key commitment in industry codes that deal with lending under the National Credit Act; that the required inquiry and verification steps be set out in RG209; that these required steps not be reduced for any credit products; and that credit providers should be audited regularly.
May 2019
Submission to: Treasury
Submission recommends that kinship be included as a specific category in legislation as an option for a binding death benefit nomination. This area of superannuation is complex, and binding death benefit nominations can be ruled invalid for a number of reasons. People of Aboriginal and Torres Strait Islander descent are very clear about their kinship relationships but are not able to choose their appropriate beneficiaries because such relationships are not legally recognised.
Submission recommends that kinship be included as a specific category in legislation as an option for a binding death benefit nomination. This area of superannuation is complex, and binding death benefit nominations can be ruled invalid for a number of reasons. People of Aboriginal and Torres Strait Islander descent are very clear about their kinship relationships but are not able to choose their appropriate beneficiaries because such relationships are not legally recognised.
April 2019
Submission to: The Treasury
March 2019
Submission to: Australian Senate
February 2019
Submission to: The Treasury Department
February 2019
Submission to: The Treasury
January 2019
Submission to: Department of Communications and the Arts
January 2019
Submission to: Customer Owned Banking Association
Independent Review of the Customer Owned Banking Code of Practice January 2019
Independent Review of the Customer Owned Banking Code of Practice January 2019
January 2019
Submission to: Financial Services Council
November 2018
Submission to: The Treasury
November 2018
Submission to: Australian Senate
This submission addresses the capacity and capability of the financial counselling sector to assist people experiencing financial stress. A separate submission was made in relation to credit and financial services targeted at Australians at risk of financial hardship.
This submission addresses the capacity and capability of the financial counselling sector to assist people experiencing financial stress. A separate submission was made in relation to credit and financial services targeted at Australians at risk of financial hardship.
November 2018
Submission to: Australian Senate
This submission addresses the terms of reference questions in relation to credit and financial services targeted at Australians at risk of financial hardship. A separate submission covers the capacity and capability of the financial counselling sector (TOR (c)) to assist people experiencing financial stress.
This submission addresses the terms of reference questions in relation to credit and financial services targeted at Australians at risk of financial hardship. A separate submission covers the capacity and capability of the financial counselling sector (TOR (c)) to assist people experiencing financial stress.
October 2018
Submission to: Royal Commission into Misconduct in the Banking, Superannuation and Financial Services Industry
October 2018
Submission to: Royal Commission into Misconduct in the Banking, Superannuation and Financial Services Industry
October 2018
Submission to: Royal Commission into Misconduct in the Banking, Superannuation and Financial Services Industry
October 2018
Submission to: Royal Commission into Misconduct in the Banking, Superannuation and Financial Services Industry
August 2018
Submission to: The Treasury
July 2018
Submission to: Australian Securities Investments Commissions
July 2018
Submission to: Royal Commission into the Banking, Superannuation and Financial Services Industry
July 2018
Submission to: The Treasury
June 2018
Submission to: Attorney General's Department
May 2018
Submission to: The Treasury
April 2018
Submission to: Australian Securities and Investments Commission
This submission provides a response to ASIC's draft Regulation Guide 139 and its oversight of the Australian Financial Complaints Authority.
This submission provides a response to ASIC's draft Regulation Guide 139 and its oversight of the Australian Financial Complaints Authority.
April 2018
Submission to: Productivity Commission
February 2018
Submission to: Senate Legal and Constitutional Affairs Legislation Committee
A submission that supports the changes proposed by the Exposure Draft of the Bankruptcy Amendment (Debt Agreement Reform) Bill 2018 and proposes further reforms.
A submission that supports the changes proposed by the Exposure Draft of the Bankruptcy Amendment (Debt Agreement Reform) Bill 2018 and proposes further reforms.
February 2018
Submission to: The Treasury
January 2018
Submission to: Insurance Council of Australia
January 2018
Submission to: Attorney-General’s Department
A response to the Bankruptcy Amendment (Enterprise Incentives) Bill 2017, supporting the reduction of the bankruptcy period from 3 years to 12 months and some ongoing obligations for bankrupts and proposing other amendments.
A response to the Bankruptcy Amendment (Enterprise Incentives) Bill 2017, supporting the reduction of the bankruptcy period from 3 years to 12 months and some ongoing obligations for bankrupts and proposing other amendments.
December 2017
Submission to: Commercial Radio Australia
December 2017
Submission to: Free TV Australia
December 2017
Submission to: Australian Subscription Television and Radio Association
December 2017
Submission to: The Treasury
November 2017
Submission to: Australian Competition and Consumer Commission
November 2017
Submission to: The Treasury
November 2017
Submission to: Australian Securities and Investments Commission
October 2017
Submission to: The Treasury
September 2017
Submission to: Australian Competition and Consumer Commission
September 2017
Submission to: The Productivity Commission
September 2017
Submission to: Victorian Commission for Gambling and Liquor Regulation
July 2017
Submission to: The Treasury
March 2017
Submission to: Senate Standing Committees on Community Affairs
January 2014
Submission to: The Treasury Department
A pre budget submission calling for continued funding for financial counselling.
A pre budget submission calling for continued funding for financial counselling.