Submission Archives - Consumer Action Law Centre

Submission supporting the re-authorisation of the Solar Code

Consumer Action has supported the Clean Energy Council (CEC)’s application for re-authorisation of the Solar Retailer Code of Conduct (the Solar Code). Principally, we support the application to avoid...

Submission: Essential Service Commission’s Electricity Distribution Code review

Consumer Action has commented on the Essential Service Commission’s (ESC) Electricity Distribution Code review – customer service standards draft decision (Draft Decision). We generally support the pr...

Submission to the Parliamentary Joint Committee’s Class Action Inquiry

Class actions provide Australians a valuable mechanism for accessing justice where systematic or repetitive conduct by the same party has caused similar harm to numerous individuals. Class actions als...

Comment to the Class Action Inquiry

Consumer Action has provided comment to the Parliamentary Joint Committee’s inquiry, Litigation funding and the regulation of the class action industry (Class Action Inquiry). Class actions p...

Submission: Maximum prices for embedded networks and other exempt sellers

Consumer Action Law Centre (Consumer Action) welcomes the opportunity to comment on the Essential Service Commission’s (ESC) Maximum prices for embedded networks and other exempt sellers Draft Decisio...

Submission to the Senate Select Committee on COVID-19

Our clients have been affected by the COVID-19 emergency, and the Australian Government’s response, in a number of ways. In many cases we have experienced a short-term decrease in demand on financi...

Submission: Bushfire Royal Commission and insurance affordability

Consumer Action’s submission to the Royal Commission into National Natural Disaster Arrangements covers the insurance and financial challenges faced by communities in the aftermath of the Black Summer...

Consumer group tells Bushfire Royal Commission that climate change is creating a perfect storm for insurance affordability

Consumer Action has warned that climate change is expected to make insurance unaffordable for many as extreme weather events hit Australia as part of its submission to the Bushfire Royal Commission re...

Joint Submission: Implementing the Royal Commission recommendations: Mortgage brokers and the best interests duty

A joint consumer submission from Consumer Credit Legal Service (WA), CHOICE,Consumer Action Law Centre, Financial Counselling Australia and Financial Rights Legal Centre. It’s time to make mortgage...

Product design and distribution obligations –ASIC Consultation Paper 325

Consumer groups have commented on ASIC’s Consultation Paper 325 – Product design and distribution obligations. We strongly support the introduction of product design and distribution obligations (DDOs...

Assessing the energy retail market’s competitiveness and efficiency

Consumer Action has provided a submission to the Essential Services Commission’s (ESC) consultation "Assessing the competitiveness and efficiency of the Victorian energy retail market" The submissi...

Treasury consultation: Enhancements to Unfair Contract Term Protections

Consumer Action has provided a joint submission to Treasury's consultation on Enhancements to Unfair Contract Term (UCT) Protections. Nearly a decade of the current UCT legislative regime has not e...

Joint submission: Re: Financial Regulator Assessment Authority Bill 2020

This is a joint consumer submission from Financial Rights Legal Centre, CHOICE and the Consumer Action Law Centre to Treasury providing comment on the Financial Regulator Assessment Authority Bill 202...

Joint submission to the Treasury re: Duty to take reasonable care not to make a misrepresentation to an insurer

This is a joint consumer submission from the Financial Rights Legal Centre, Consumer Action Law Centre, CHOICE, the Public Interest Advocacy Centre, Financial Counselling Australia, and the Consumer C...

Joint submission: Exposure draft – Deferred sales model for add-on insurance – FSRC Rec 4.3

This submission has been prepared by Consumer Action Law Centre with contributions and endorsement from Financial Rights Legal Centre, Financial Counselling Australia, CHOICE, Consumer Credit Law Cent...

Joint submission: Exposure draft – No hawking of financial products – FSRC Rec 3.4 and 4.1

This submission has been prepared by Consumer Action Law Centre with contributions and endorsements from Financial Rights Legal Centre, CHOICE, Consumer Credit Legal Service (WA), and Financial Counse...

Joint submission: Strengthening breach reporting

This is a joint consumer submission from Consumer Credit Legal Service (WA), CHOICE, Consumer Action Law Centre and Financial Rights Legal Centre. We strongly support proposed reforms to the breach re...

Joint submission: Enforceability of financial services industry codes

This is a joint submission by Financial Rights Legal Centre, the Consumer Action Law Centre, CHOICE, Financial Counselling Australia, Consumer Credit Legal Service (WA) and the Consumers’ Federation o...

Joint submission re: Exposure Draft Implementation of ASIC Enforcement Review Taskforce – Directions Power

This submission has been drafted by Consumer Action Law Centre with contributions and endorsement from Financial Rights Legal Centre, CHOICE, Consumer Credit Legal Service (WA), and Financial Counsell...

Joint submission re: Exposure Draft: Cap on vehicle dealer commissions

This submission has been drafted by Consumer Action Law Centre with contributions and endorsement from Financial Rights Legal Centre, CHOICE, Financial Counselling Australia, and Consumer Credit Legal...

Joint submission: Financial Services Royal Commission Recommendations 4.6 – Limiting avoidance of life insurance contracts

Joint submission: Financial Services Royal Commission Additional commitment in response to Recommendation 4.2 – Restricting the use of the term ‘insurance’ and ‘insurer’

This is a joint submission from the Financial Rights Legal Centre, Consumer Action Law Centre, CHOICE, Financial Counselling Australia and Consumer Credit Legal Service (WA) and provides comment on th...

Joint submission: Re: Ongoing fee arrangements and disclosure of lack of independence

This is a joint consumer submission from Financial Rights Legal Centre, CHOICE and the Consumer Action Law Centre. Read the full submission [here] ...

Households in embedded networks need fair electricity prices
Maximum prices for embedded networks and other exempt sellers Consultation Paper

Households in embedded networks are often in effective monopoly situations with little regulatory oversight. For this reason, they need the same or better protections than their peers with conventiona...

Time’s up: Government must step up and pass payday lending and rent-to-buy reforms
Submission to the Senate Economics Legislation Committee

Consumer Action's submission to the Senate Economics Legislation Committee calls on Parliament to pass the National Consumer Credit Protection Amendment (Small Amount Credit Contract and Consumer Leas...

Establishing a Compensation Scheme of Last Resort

Consumer groups have made a joint submission to the Treasury’s Discussion Paper, Implementing Royal Commission Recommendation 7.1 – Establishing a Compensation Scheme of Last Resort (December 2019). T...

Maintain households’ rights when accessing essential energy services
Australian Energy Market Commission Issues Paper 2; Consumer Protections in an Evolving Market: Traditional Sale of Energy - 2020 Retail Energy Competition Review

As new energy products and services create more options for consumers to access energy offers with non-conventional pricing or features, the complexity of making decisions increases and poses more ris...

Implement strong protections to ensure households benefit from new energy technology
Australian Energy Market Commission Issues paper one: Consumer Protections in an Evolving Market: New Energy Products and Services - 2020

Consumer Action’s legal and financial counselling services have regularly assisted consumers experiencing harm as solar technology grows in popularity in Victoria. Our Power Transformed, Knock It Off!...

Delivering on the promise to ban vendor terms and rent-to-buy agreements from Victoria’s housing market
Consumer Affairs Victoria – Sale of Land (Exemption) Regulations 2020, Implementation Consultation

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...

Critical moment to fix and prevent systemic mis-selling of junk insurance and warranties through caryards
Australian Securities and Investments Commission – Product intervention: The sale of add-on financial products through caryard intermediaries

Since 2016, Consumer Action’s free tool, DemandaRefund.com has helped people to generate over 9,000 demands totalling an estimated $17 million in refunds for junk consumer credit insurance (CCI), guar...

RBA Review of Retail Payments Regulation

The payments landscape has changed rapidly since the RBA’s last review of retail payment systems five years ago. The emergence of new payment schemes, such as buy now, pay later (BNPL) has skewed the...

Energy contracts can only be fair if all Victorian energy users have the same protections
Essential Services Commission – ‘Ensuring energy contracts are clear and fair’ draft decision

Despite the introduction of the Victorian Default Offer for electricity, the state’s most vulnerable energy consumers still face challenges in the market. Energy prices changing unexpectedly, excessiv...

Remove barriers to energy efficiency for rental properties
Department of Environment, Land, Water and Planning - Discussion Paper; Options for Addressing Risks from Open Flued Gas Space Heaters in Victoria – Letter of Support for Tenants Victoria Submission

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 rental properties or disputes with re...

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...

Making the insurance claims process fair
The Treasury – Making insurance claims handling a financial service – Financial Services Royal Commissions Recommendation 4.8

From a consumer perspective, claims handling is the most critical part of the insurance process, and one of the most problematic. Too often, the claims process is arduous, lengthy and unfair. In ou...

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

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...

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