Joint submission with Financial Counselling Australia and the Consumer Credit Legal Service (WA) to ASIC’s Consultation Paper on an online database for small amount lenders.
The Consumer Action Law Centre, Consumer Credit Legal Service Western Australia and Financial Counselling Australia welcomes the opportunity to comment on ASIC Consultation Paper 198: Review of the Effectiveness of an Online Database for Small Amount Lenders.
Briefly, our submission:
- supports the development of a small amount credit contract loans database (or a similar system) because it will be very difficult to ensure compliance with the new responsible lending presumptions to be introduced on March 1 2013;
- acknowledges that colleagues in other consumer and privacy advocacy organisations hold privacy concerns about the database proposal but considers that these concerns can be addressed by careful design of the database;
- recommends that Government continue to investigate the details of how an online database would work (including how personal information of consumers would be protected) and also consider the costs and benefits of alternatives including systems based in the existing credit reporting system; and
- responds to the questions in the consultation paper.