Advocacy Activities

We represent our members to shape positive industry change - lifting the voice of the industry through active engagement with all political parties and submissions to Government and regulators on legislative reform, change and frameworks. We lift the industry voice through sophisticated partnerships to influence policy and regulatory developments, contribute to public debates, promote policy and data through modern advocacy techniques, and foster our industry leaders.

Every conversation and movement we make within our operations is in some way aimed at achieving a fair and just outcome for our members and their customers and making sure we are well-positioned to manage the inevitable cycles of further change as a new financial services landscape takes shape.

COVID-19 Advocacy

Over the past six months, AFIA has worked closely with the Federal Government, including, Treasury, financial regulators, state and territory governments, through to the National Cabinet, Australian Office of Financial Management (AOFM), as well as other key stakeholders on a range of issues, including actions necessary to address the immediate impact of the COVID-19 crisis on our economy and community. AFIA collaborates with:

• the Deputy Prime Minister on Government and industry support for AFIA car rental operators
• Treasury on the SME Guarantee Scheme  I and II and Initiatives to support smaller lenders support their customers through our recovery
• the Treasurer on the initial Government’s stimulus package and other measures to support the Australian economy
• the Treasurer on relief measures for the most impacted part of our economy
• the Treasurer on additional inform and data re JobKeeper program and support for smaller lenders
• the Treasurer on AFIA’s recommendations as part of pre-budget submissions
• Treasury on the SME Guarantee Scheme  I and II and Initiatives to support smaller lenders support their customers through our recovery
• the Chair of the National COVID-19 Coordination Commission on smaller lenders supporting a fast and broad economic recovery in Australia
• the Senate Select Committee on COVID-19 inquiry into the Australian Government’s response to the COVID-19 pandemic
• Senator Michaelia Cash, Minister for Employment, Skills, Small and Family Business’ office in Industry roundtables
• Senator Jane Hume, Assistant Minister for Superannuation, Financial Services and Financial Technology Industry roundtables
• the NSW Government on supporting a fast and broad economic recovery in NSW and across Australia
• the Victorian Premier on initiatives to ensure compliance by AFIA members with Stage 4 restrictions
• the AOFM on the Structured Finance Support Fund (SFSF) and the Forbearance Special Vehicle as well as a multi-seller scheme to assist the AOFM to manage the pipeline of applications.

You can read about some of our COVID-19 advocacy work here.

Financial Services Royal Commission Recommendations

AFIA continues its work on Financial Services Royal Commission related work, making submissions on a number of pieces of exposure draft legislation responding to the Royal Commission recommendations on:

• ASIC’s directions powers
• strengthening of breach reporting
• enforceability of financial services industry codes
• deferred sales model for add-on insurance
• cap on vehicle dealer commissions
• compensation scheme of last resort
• financial accountability regime.

AFIA has participated in Treasury Roundtables and targeted consultations on the proposed Strengthening Breach Reporting regime and was instrumental in working with Treasury on the deferment of Royal Commission related reform initiatives for 6 months to allow industry to manage the impact of the pandemic.

See below for further detail regarding our RC related work:

• FSRC submission
• Extra addendum on Strengthening Breach Reporting
• CSLR Submission
• FAR Submission

Reserve Bank of Australia

AFIA provided a submission in response to the Reserve Bank of Australia’s (RBA) Review of Retail Payments Regulation Issues Paper (the Issues Paper) as well as engaging privately with the RBA. For further reading, please see here.

AFIA continues to work collaboratively with key industry regulatory bodies, including the Australian Securities and Investments Commission (ASIC) on issues and initiatives relating to the industry including:

• Relief for Point of Sale Business Managers during COVID 19
• ASIC’s scope of its Product Intervention Power (PIP)  
• Proposed application of PIP to Add-on insurances & warranties member consultations & submission
  
• Design and distribution obligations member consultations & submission
  
• Updated guidance on Internal Dispute Resolution

AFIA also continues to work with other regulators such as AUSTRAC on its draft ML/TF risk assessment on the non-bank lending and finance sector, as well as the ACCC on Open Banking and the Consumer Data Right consultations.

 
AFIA works with a range of industry stakeholders, including:

• The Australian Small Business and Family Enterprise Ombudsman on issues impacting SME business’ access to credit.
• Meeting regularly with the Australian Financial Complaints Authority on key industry issues, such as the latest complaint statistics and trends, upcoming ‘Fairness Project’ consultation, and AFCA’s approach to certain issues.
• Meeting regularly with a group of Consumer Advocates (includes Consumer Action Law Centre, Financial Rights Legal Centre, Legal Aid QLD, Legal Aid NSW, Consumer Credit Legal Service WA) to discuss key issues facing the industry and its consumers.
• Participating in the Combined Industry Forum to which AFIA is a member.
• Participating in the Department of Home Affairs Critical Infrastructure Centre’s Trusted Information Sharing Network (TISN) to which AFIA is a member of the Banking and Finance Sector Group.
  
  

At the 2019 Banking and Oath Conference, Wayne Byers, Chairman of the Australian Prudential Regulation Authority in his Speech 'Self- Regulation Dead'  talked about the value of self-regulation and industry stepping up to take ownership in areas of governance, customer service and technical standards.  

We work together with our members to develop industry standards (Codes of Practice) in order to improve transparency, fairness and customer confidence. These practices assist members to meet community standards and their legal obligations, as well as lift practices for a better future for finance.

AFIA currently administers the AFIA Online Small Business Code of Lending Practice, the Car Rental Conciliation Code, the Buy Now Pay Later Code of Conduct and is currently assisting its members to establish an Insurance Premium Funding Code of Conduct. Additionally, we will soon be commencing work on a Salary Packaging Code of Practice.