The Consumer Action Law Centre welcomes the opportunity to comment on the implementation of the prohibition on flex-commissions Consultation Paper (the Consultation Paper).
We generally support the prohibition on flex-commissions in the ASIC Credit (Flexible Credit Cost Arrangements) Instrument 2017/780 (the Instrument) and proposed amendments. However, we consider that the Instrument could be strengthened in several areas. In particular, we recommend that the 200-basis point ‘reverse flex’ arrangement under section 5(b) of the Instrument be removed.
Read the full submission here [PDF].180522 Flex Commissions submission