Unfair Trading Practices – Exposure Draft and Explanatory Memorandum
We are providing this supplementary submission to Treasury, to highlight the need to explicitly consider manipulative lead generation practices in the Exposure Draft legislation and Explanatory Memorandum to ensure its status as an unfair trading practice is clear.
To ensure the Unfair Trading Practices prohibition functions as intended and genuinely protects consumers from unfair conduct, consideration should be given to reversing the onus of proof to place on businesses, the burden of proving a practice is fair.
Read the full submission (PDF).
200226 Letter UTP exposure draft leg