Submission: Implementation of prohibition on flex-commissions

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
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