Thank you for the opportunity to provide feedback on the proposed amendments to retirement village fact sheets.
Consumer Action, RRVV, HAAG and COTA Vic do not oppose the proposed amendments to the fact sheets. However, we reiterate our concerns, which we have raised in previous submissions, that disclosure alone will not solve the problems in this sector.
In addition to reading highly complex legal documents that often exceed 100 pages in length, residents are expected to read fact sheets, disclosure statements, the CAV website and the CAV guide in order to properly ‘inform’ themselves. Not only is this unrealistic, but it ignores significant academic research that indicates that disclosure is an ineffective consumer protection tool. Instead, we need to address the underlying unfairness and complexity of this market.171207 Submission - amendments to RV fact sheets