We are pleased to make a submission in regards to the Exposure Draft Bill (the Bill) and Explanatory Materials implementing the Government’s response to the Small Amount Credit Contracts Review (the Review).
We strongly support the proposed reforms to small amount credit contracts (SACCs) and consumer leases. Our organisations were actively involved in the consultation period of the Review, and some of our submissions were noted in the Review Final Report. We regard the proposed cap on costs for consumer leases, and the 10% protected earnings amount for consumer leases and payday loans as particularly critical reforms that would provide much needed protections for vulnerable borrowers. We would strongly oppose more lenient caps, which would entrench ongoing financial exclusion and fail to address the harm caused by these products.
Where this submission is silent on proposed reforms, we can be taken as being supportive. Our additional comments below relate largely to technical amendments.171103 FINAL submission - exposure draft SACC legislation