Submission Archives - Consumer Action Law Centre

Strengthening consumers’ voice in policy and regulation affecting superannuation
The Treasury – Consumer Advocacy Body for Superannuation: expression of interest

Choosing a superannuation fund is one of the most important financial decisions a person will make. However, the superannuation system is failing countless Australians. People across Australia cont...

FinTech and RegTech should support positive outcomes for consumers
Senate Select Committee on Financial Technology and Regulatory Technology – Inquiry into Financial Technology and Regulatory Technology

While we support the development of innovative services and business models that genuinely meet the needs of consumers much of the existing legal and regulatory frameworks are no longer fit for purpos...

Lack of minimum efficiency standards put renters at greater risk of energy debts
Department of Justice and Community Safety - Residential Tenancies Regulations 2020 Regulatory Impact Statement

The financial counsellors working on Consumer Action's National Debt Helpline service provided financial counselling to over 11,000 people in the 2018/19 financial year. Often issues with low quality...

Strong compliance and enforcement is needed in telecommunications industry
Australian Communications and Media Authority - ACMA compliance priorities 2020-21 (consultation 36/2019)

Consumer Action receives 2-3 new calls per week through our legal assistance and worker advice lines or the National Debt Helpline about clients who are negatively affected by unaffordable phone debt....

Enhanced protections and clearer responsibilities will better support retirees
Engage Victoria – ‘Review of the Retirement Villages Act 1986’ Issues Paper

There are many systemic issues exist with retirement housing that adversely affect retirees’ wellbeing in their golden years. These include housing providers using threats of eviction to discourage re...

Giving energy users access to fair finance for new energy tech
AA1000439 - New Energy Tech Consumer Code - consultation proposed amendments to draft code

Consumer Action Law Centre (Consumer Action) welcomes the opportunity to comment on the AA1000439 – New Energy Tech Consumer Code— consultation on proposed amendments to draft Code (Proposed Amendment...

Insurance pricing differences: New vs existing customers

Local councils must take financial hardship into account when collecting rates
Local Government Rating System Review

Financial counsellors assist clients who are experiencing financial hardship. Most of WEstjustice’s and Consumer Action’s clients are grappling with debts and meeting the high cost of living in Melbou...

Access to basic bank accounts essential for vulnerable banking customers
ACCC – ABA Application for authorisation AA10000441, Amendments to the 2019 Banking Code of Practice, 31 October 2019 response

In our joint submission with Financial Rights Legal Centre (Financial Rights) and Financial Counselling Australia (FCA), we offered strong support for the conditions proposed by the ACCC in its Draft...

Effective banking codes require enforcement measures with teeth
Customer Owned Banking Association – Report Three of the independent review of the Customer Owned Banking Code of Practice

In our joint submission with Financial Rights Legal Centre to Report Three of the Customer Owned Banking Association’s (COBA) independent review of the Customer Owned Banking Code of Practice (COBA Co...

Good consumer outcomes should not be sacrificed for bankers’ bonuses
Australian Prudential Regulation Authority – Consultation on remuneration requirements for all APRA-regulated entities

The financial services industry plays an essential role in the lives of Australians, from providing for day-to-day transactions to providing for a comfortable retirement. Markets were opened becaus...

Funeral expenses only products must be held to a higher standard
The Treasury - Removal of the exemption for funeral expenses policies, Exposure draft legislation

Consumer advocates have held long standing concerns over the inadequate regulatory framework for funeral expenses products. In our joint submission with Financial Rights Legal Centre (Financial Rig...

All Victorians deserve access to fair energy pricing
Essential Service Commission – Victorian Default Offer to apply from 1 January 2020 Draft Decision

Since its implementation on 1 July 2019, the Victorian Default Offer (VDO) has given more Victorian energy users access to fairer pricing for their essential electricity services. In our comment to...

Protecting Australian families from dodgy vendor terms and rent-to-buy arrangements
Consumer Affairs Victoria – Implementation consultation for the Sale of Land Amendment Act 2019

Over the years, our team has assisted a number of people who have been adversely affected by failed vendor finance and rent-to-buy deals, which are promoted as an opportunity to achieve home ownership...

Energy compliance and performance reporting guideline
Essential Services Commission – Compliance and Performance Reporting Guideline updated to include new entitlements for customers Draft Decision

Monitoring is only as effective as the information gathered. In our submission to the Essential Services Commission (ESC) Compliance and Performance Reporting Guideline updated to include new entit...

Financial product design and distribution obligations must be consumer centred and limit loopholes
The Treasury – Corporations Amendment (Design and Distribution Obligations) Regulations 2019 (Cth)

The Design and Distribution Obligations (DADOS) require financial service providers to provide products that meet customer needs rather than focussing on securing the sale. In our joint submission on...

ASIC Enforcement Review
Australian Securities and Investments Commission - Exposure draft legislation, ASIC Enforcement Review Taskforce Final Report

In our joint response to exposure draft legislation implementing certain aspects of the ASIC Enforcement Review Taskforce (ERT) Final Report, Consumer Action and Financial Rights Legal Centre (Financi...

Customer-owned banking code must adequately address financial vulnerability
Customer Owned Banking Association – Report Two of the independent review of the Customer Owned Banking Code of Practice

In our joint submission with Financial Rights Legal Centre to the Report Two of the Customer Owned Banking Association’s (COBA) independent review of the Customer Owned Banking Code of Practice (COBA...

Making it easier for vulnerable customers to access fee-free banking
Australian Competition and Consumer Commission – Draft Determination AA1000441, Australian Banking Association application for authorisation of certain amendments to the 2019 Banking Code

Access to fee-free ‘basic bank accounts’ are an important support for vulnerable banking customers. In light of the harm banking fees can cause for low-income and vulnerable consumers, Commissioner Ha...

Submission: Inquiry into credit and financial services targeted at Australians at risk of financial hardship

Reforming the sale of add-on insurance
Treasury - Reforms to the sale of add on insurance: Proposal Paper

Seven leading consumer groups commented on The Treasury’s Reforms to the sale of add on insurance: Proposal Paper: Consumer Action Law Centre Financial Rights Legal Centre CHOICE Consume...

National Energy Retail Amendment (Strengthening Protections for Customers in Hardship) Rule 2018 Draft Rule Determination

The mortgage broking industry is long overdue for reform
The Treasury – Mortgage broker best interests duty and remuneration reforms

The mortgage broking industry is long overdue for reform. Landmark inquiries from the Banking Royal Commission and the Productivity Commission, as well as a number of ASIC investigations, have all...

Energy regulators should have strong powers to stop misconduct
Treasury - Treasury Laws Amendment (Prohibiting Energy Market Misconduct) Bill 2019

Consumer Action supports the Treasury Laws Amendment (Prohibiting Energy Market Misconduct) Bill 2019 (the Bill). We feel that it will ensure the Australian Energy Regulator (AER) has appropriate powe...

Royal Commission into Mental Health Terms of Reference Consultation

Cashless Debt Card undermines the role of the market in serving consumer and community interests
Senate Community Affairs Legislation Committee – Social Security (Administration) Amendment (Income Management to Cashless Debit Card Transition) Bill 2019

Much of the Federal Government’s effort to address cost of living pressures involves making it easy to switch and exercise choice, for example, through the new Consumer Data Right. However, the Cashle...

Fairness needs to be at the forefront of the energy market
Energy Security Board - Post 2025 Market Design Issues Paper

It is our firm stance that fairness should be at the forefront of all markets. In our comment on the Energy Security Board (ESB) Post 2025 Market Design Issues Paper (Issues Paper), Consumer Action...

Giving energy users access to fair finance for new energy tech
Australian Competition and Consumer Commission - AA1000439 New Energy Tech Consumer Code Application

On 9 September 2019, Consumer Action attended a pre-decision conference on AA1000439 New Energy Tech Consumer Code (The Code) Application. We have provided a further submission following the discussio...

Making sure Victorian energy is safe for those requiring power for life support purposes
Essential Service Commission - Strengthening protections for life support customers draft decision

Most people would take the reliability of electricity services for granted. When the power goes out, it is frustrating, but not life threatening. But for many Australians, a loss of electricity is...

Looking after the needs of Victorian energy consumers
Energy and Water Ombudsman Victoria - Independent Review

The Energy & Water Ombudsman Victoria (EWOV) plays an important role in ensuring Victorian households have ongoing access to fair outcomes in relation to the provision of essential energy and wate...

Keeping energy market prices down during energy shortages or network constraints
Australian Energy Market Commission - Draft determination allowing demand response service providers to participate in the wholesale energy market

Demand response service providers could play an important role in the event of energy shortages, coordinating high energy users to consumer less to help keep energy prices down across the market. Curr...

Preparing vulnerable Victorians for electricity outages
Essential Services Commission - Electricity Distribution Code Review Issues Paper

Consumers rely on energy distribution businesses to ensure a consistent supply of their essential electricity services. It is important that these businesses are regulated effectively so that consist...

Keeping comprehensive credit reporting fair for those who have previously experienced hardship
Treasury - National Consumer Credit Protection Amendment (Mandatory Comprehensive Credit Reporting) Bill 2019

Leading consumer advocacy bodies are concerned that customers who experience financial difficulty repaying loans will be unfairly penalised by credit reporting reforms proposed by the National Consume...

Submission: Telecommunications Consumer Safeguards Review Part A – Consumer Redress and Complaints Handling

The norm of fairness must be recognised
Final Report of the Australian Competition & Consumer Commission Digital Platforms Inquiry

Our existing consumer protection framework has failed to prevent unfairness from becoming embedded in business practices. From unclear marketing, subscriptions that make cancellation difficult, to...

Closing the ‘unfair contract terms’ loophole for insurance – Exposure draft legislation
Treasury - Consultation on Extending Unfair Contract Terms to Insurance Contracts

There is a big fairness problem in insurance. People often make insurance claims when they are at a low ebb, but they can face shocking outcomes when insurers rely on unfair terms in insurance contrac...

ASIC’s proposed ban on outbound phone sales of life, funeral and consumer credit insurance
Australian Securities and Investments Commission - Consultation Paper 317, Unsolicited telephone sales of direct life and consumer credit insurance

Unsolicited selling is an outdated and abusive practice with a significant risk of mis-selling people products they don’t want, need or understand. Financial Rights Legal Centre and Consumer Action...

Response to ASIC’s update to internal dispute resolution requirements for financial firms (RG165)
Australian Securities and Investments Commission - Consultation Paper 311, Internal Dispute Resolution: Update to Regulatory Guide 165 (May 2019)

It is critical that the process to make and resolve complaints with a bank, insurer, or super fund is timely, fair, and accessible, including for people experiencing vulnerability and disadvantage. O...

Support for an independent review of the Customer Owned Banking Code of Practice
Customer Owned Banking Code of Practice Independent Review, Report One

In our joint submission with Financial Rights Legal Centre, Consumer Credit Legal Service (WA), Financial Counselling Australia and the Financial & Consumer Rights Council, we support Cameron Ralp...

New Energy Tech Consumer Code must protect Australians from exploitative buy now pay later arrangements
Australian Competition and Consumer Commission - AA1000439 New Energy Tech Consumer Code Application for Authorisation Draft Determination

Consumer Action regularly assists vulnerable and disadvantaged consumers in Victoria with legal and financial issues that arise due to new energy technology such as solar. . The New Energy Tech Consu...

Protecting guarantors from financial abuse
Banking Code Compliance Committee - Inquiry into banks’ compliance when accepting and enforcing guarantees

In our feedback to the Banking Code Compliance Committee (BCCC) inquiry into banks’ compliance when accepting and enforcing guarantees, Consumer Action discusses our concerns with guarantee provision...

Victorian Default Offer to apply from 1 January 2020 Issues Paper
Essential Service Commission - Victorian Default Offer to apply from 1 January 2020 Issues Paper

The Victorian Default Offer (VDO) was designed to re-regulate electricity pricing to ensure that more Victorian households receive a fair price on their electricity service. Since the VDO’s establishm...

ASIC Consultation Paper 313: Product intervention power
Australian Securities and Investments Commission - Consultation Paper 313: Product Intervention Power

We welcome the introduction of the product intervention power (PIP) and look forward to ASIC using the power to target businesses that cause consumer detriment by engaging in predatory conduct or fail...

ASIC Consultation Paper 316: Using the product intervention power: Short term credit
Australian Securities and Investments Commission - Consultation Paper 316: Using the product intervention power: Short term credit

Businesses such as Cigno Pty Ltd, which facilitate access to predatory and unregulated payday loans by exploiting loopholes in the law, are on notice as the Australian Securities and Investment Commis...

Insurance in super: Putting Members’ Interests First Bill 2019
Senate Economics Legislation Committee - Inquiry into provisions of the Treasury Laws Amendment (Putting Members’ Interests First) Bill 2019

Consumer Action Law Centre and Financial Rights Legal Centre made a joint submission to the Senate Economics Legislation Committee’s inquiry into provisions of the Treasury Laws Amendment (Putting Mem...

Victoria’s Mental Health Royal Commission must examine links between links between poverty, debt and mental health
Royal Commission into Victoria’s Mental Health System

Consumer Action’s financial counsellors and lawyers speak regularly to individuals experiencing mental health issues. These individuals are commonly trying to deal with a range of consumer problems in...

Ensuring energy contracts are clear and fair, ESC Issues Paper
Essential Services Commission - Ensuring Energy Contracts are Clear and Fair Issues Paper

Deregulation in Victoria’s energy retail market has not delivered fair outcomes for all households accessing their essential energy services. The State Government has taken a number of steps to hel...

Comment on the ACCC’s authorisation of amendments to the 2019 Banking Code of Practice
Australian Competition and Consumer Commission - Authorisation of amendments to the 2019 Banking Code of Practice

Consumer Action Law Centre (Consumer Action), the Financial Rights Legal Centre (Financial Rights) and Financial Counselling Australia (FCA) have provided comment on the Australian Banking Association...

Banks should recognise that anyone can become vulnerable: Submission to ABA Guideline on Customer Vulnerability
Australian Banking Association - ‘Every Customer Counts: Better banking for vulnerable customers’ Guideline

There are any number of reasons why a person would be unable to unwilling to speak up when they are struggling with their financial situation. Who among us hasn’t faced a financial issue at one poi...

Essential Services Commission Consequential amendments related to the Victorian Default Offer Draft Decision
Essential Services Commission - Draft Decision on the Consequential Amendments Related to the Victorian Default Offer

Generally, we strongly support this Draft Decision as it makes clear that energy retailers must ensure that they inform households in Victoria of new protections and options available when choosing an...

New Energy Tech Consumer Code ACCC application
Australian Competition and Consumer Commission - AA1000439 New Energy Tech Consumer Code

Energy is an essential service and the energy system is rapidly transitioning to new technologies. Householders are finding it increasingly complex, confusing and risky to make decisions about their e...

ASIC must overhaul responsible lending guidance to protect Australians
Australian Securities and Investments Commission - Response to CP309: Update to RG209: Credit licensing: Responsible lending conduct

Consumer Action Law Centre (Consumer Action) has called on the Australian Securities and Investment Commission (ASIC) to urgently overhaul responsible lending guidance to better protect Australians fr...

Proposed AFCA arrangements for comparative reporting of complaint data
Australian Financial Complaints Authority - Proposed AFCA arrangements for comparative reporting of complaint data

Comparative reporting of data related to complaints against financial service providers will empower consumers to make informed decisions about where to take their business. Consumer Action Law Centr...

ACCC Northern Australia Insurance Inquiry First Interim Report
Australian Competition and Consumer Commission - Northern Australia Insurance Inquiry – First Interim Report

Consumer Action Law Centre (Consumer Action) strongly supports the Australian Competition and Consumer Commission’s (ACCC) important work on insurance pricing and the operation of insurance markets in...

Insurance Claims Handling: Taking Action on Recommendation 4.8 of the Banking, Superannuation & Financial Services Royal Commission
The Treasury - Insurance Claims Handling: Taking Action on Recommendation 4.8 of the Banking, Superannuation & Financial Services Royal Commission, March 2019

Claims handling is the most critical part of the insurance process for many consumers. Unfortunately, ‘legal loopholes’ have caused undue stress and delayed resolutions for too many consumers in thei...

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