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AFIA Submissions


We represent members’ views to shape positive industry change - driving public policy debate through active engagement with all political parties via submissions to Government and financial regulators on legislative reform, change and frameworks, and extensive stakeholder consultation via our leadership and working groups.

16

Mar 2023

AFIA Submission to Treasury on Electronic Precontractual Disclosures

On 16 March 2023, AFIA made a submission to this Treasury consultation. The consultation included proposed amendments to the National Consumer Credit Protection Act 2009 (Cth)(the Credit Act)…

17

Feb 2023

Designing Australia's Sustainable Finance Taxonomy

On 17 February 2023, AFIA made a submission to the framing paper on ‘Designing Australia’s Sustainable Finance Taxonomy’. AFIA welcomes the recommendations to help to set out…

17

Feb 2023

Climate-related financial disclosure

On 17 February 2023, AFIA made a submission to the Climate-related financial disclosure consultation paper. AFIA supports the Australian Government’s commitment to a sustainable finance…

10

Feb 2023

AFIA Submission to Treasury - Regulating BNPL in Australia

AFIA today released its submission to Treasury’s Options Paper: Regulating Buy Now, Pay Later in Australia. AFIA welcomed the Government’s recognition of the important role of BNPL…

7

Feb 2023

Strategic Plan for the Payments System: Consultation Paper

On 7 February 2023, AFIA made our submission to Treasury’s consultation on the Strategic Plan for the Payments System. In that submission AFIA supported the Government’s principl…

1

Feb 2023

Consumer Data Right rules and data standards design paper for non-bank lending sector

On 1 February 2023, AFIA made our submission to Treasury’s ongoing consultation on the extension of the Consumer Data Right (CDR) to the Non-Bank Lending (NBL) sector. Some important p…

16

Dec 2023

Financial Counselling Industry Funding Model - Discussion Paper

AFIA made a submission to the Department of Social Services on their Financial Counselling Funding Model Discussion Paper. The submission supports the aim of increasing the availability of fre…

31

Oct 2022

National Electric Vehicle Strategy (NEVS)

On 31 October 2022, AFIA made a submission to the National Electric Vehicle (EV) Strategy. AFIA’s recommended proposals to encourage the uptake of EVs, including measures to stimulate de…

28

Oct 2022

ASIC Industry Funding Model (IFM)

On 28 October 2022, AFIA made a submission on the Australian Securities and Investments Commission (ASIC)’s IFM. Our suggestions are designed to ensure the IFM is levied in a way which i…

24

Oct 2023

CDR Action Initiation

AFIA made a submission to Treasury on exposure draft legislation to enable action initiation in the Consumer Data Right. The submission supports the introduction of action initiation as the ne…

14

Oct 2023

CDR Expansion to telecommunications and operational enhancements

AFIA made a submission to Treasury on exposure draft amendments to the Consumer Data Right to expand to telecommunications and implement operational improvements. The submission welcomes the o…

7

Oct 2022

Financial Services Compensation Scheme of Last Resort

On 7 October 2022 AFIA made a submission to Treasury’s consultation on the proposed Financial Services Compensation Scheme of Last Resort (CSLR). AFIA supports the CLSR and made recomme…

7

Oct 2022

Financial Accountability Regime Minister Rules 2022

On 7 October 2022 AFIA made a submission to Treasury’s consultation on the proposed Minister’s Rules for the Financial Accountability Regime (FAR). The FAR would extend obligations…

20

Sep 2022

Treasury Consultation on Improving Corporations and Financial Services Law

AFIA has lodged a submission to Treasury’s consultation on Improving Corporations and Financial Services Law. This submission reflects AFIA’s support for the implementation of reco…

19

Sep 2022

AFIA Submission to Treasury on the Consumer Data Right Non Bank Lending Draft Designation Instrument

19 September 2022 AFIA has lodged a submission to Treasury’s consultation for Consumer Data Right – Non-Bank Lending draft designation instrument. The submission reflects AFIA&rsqu…

17

Aug 2022

Inquiry into the Treasury Laws Amendment (Electric Car Discount) Bill 2022

AFIA has lodged a submission to the Senate Economics Legislations Committee’s inquiry into the Treasury Laws Amendment (Electric Car Discount) Bill 2022. This submission reflects AFIA&rs…

1

Aug 2023

Consultation Outcome on the Regulation of Buy Now Pay Later

AFIA made a submission to HM Treasury on Regulation of Buy Now Pay Later: response to consultation. The submission sets out the economic and consumer benefits of Buy Now Pay Later Products, an…

14

Apr 2022

Treasury's CDR Sectoral Assessment for the Open Finance Sector

14 April 2022 AFIA has lodged a submission to Treasury’s CDR Sectoral Assessment for the Open Finance sector - Non-Bank Lending.

The submission reflects AFIA’s support…

29

Mar 2022

Consumer Financial Protection Bureau BNPL Inquiry March 2021

29 March 2022 AFIA has provided a submission to the Consumer Financial Protection Bureau in the United States in response to the CFPB’s public request for comments on its inquiry into th…

4

Mar 2022

The Australian Business Securitisation Fund

4 March 2022 AFIA provided a submission to the review of the Australian Business Securitisation Fund (ABSF) capturing the experiences and views of members as well as some ideas about how the i…

28

Feb 2022

APRA Information Paper: Macroprudential Policy Framework

28 February 2022
AFIA appreciates the opportunity to provide this submission on the APRA Information Paper: Macroprudential Policy Framework. Download Submission

23

Feb 2022

OAIC Review of the Privacy (Credit Reporting) Code 2014

23 February 2022
AFIA appreciates the opportunity to provide feedback to the Office of the Australian Information Commissioner in relation to the Privacy (Credit Reporting) Code 2014 (Ve…

11

Feb 2022

CP 350 - Consumer Remediation: Further Consultation

11 February 2022
AFIA appreciates the opportunity to provide our submission to the Australian Securities and Investments Commission on CP 350 - Consumer Remediation: Further Consultation…

8

Feb 2022

CP 354: ASIC Relief for Simple Arrangements Following a Credit Hardship Notice

8 February 2022
AFIA appreciates the opportunity to provide feedback to the Australian Securities and Investments Commission (ASIC) on CP 354: ASIC relief for simple arrangements followi…

28

Jan 2022

2022 Federal Budget

28 January 2022
AFIA appreciates the opportunity to provide our submission to the Assistant Treasurer for consideration in preparing the 2022-23 Federal Budget. Download Submission

25

Jan 2022

CP 355 Product Intervention Orders: Short Term Credit and Continuing Credit Contracts.

25 January 2022
AFIA appreciates the opportunity to make a submission to the Australian Securities and Investments Commission on CP 355 Product Intervention Orders: Short Term Credit and…

24

Jan 2022

Online Privacy Bill Exposure Draft - Request for Additional Feedback

24 January 2022 AFIA appreciates the opportunity to provide additional feedback to the Attorney-General’s Department’s (AGD) consultation on the Online Privacy Bill Exposure Draft.…

19

Jan 2022

ACCI Submission: Extend the Power of the AAT to Pause or Modify ATO Debt Recovery Action

19 January 2022
AFIA has provided input to the Australian Chamber of Commerce and Industry (ACCI) submission on the government’s exposure draft legislation to allow small business…

10

Jan 2022

Regulation of Buy Now Pay Later - UK Consultation

10 January 2021 AFIA appreciates the opportunity to make a submission to HM Treasury's Regulation of Buy Now Pay Later Consultation, released in October 2021. Download Submission

17

Dec 2022

ACCI Submission: Regional Banking Taskforce - Issues Paper

17 December 2021
AFIA has provided input to the Australian Chamber of Commerce and Industry (ACCI) submission on the Treasury's Regional Banking Taskforce - Issues Paper. Access the full…

16

Dec 2022

Buy Now Pay Later - NZ Discussion Document

16 December 2021 AFIA appreciates the opportunity to provide a submission to the Ministry of Business, Innovation and Employment (MBIE) Discussion Document about Buy Now Pay Later (BNPL) produ…

28

Sep 2021

Contribution of Tax and Regulation on Housing Affordability and Supply

AFIA appreciates the opportunity to make a submission to the House of Representatives Standing Committee on Tax and Revenue inquiry into the contribution of tax and regulation on housing affor…

20

Sep 2021

Strengthening Protections Against Unfair Contract Terms

20 September 2021 AFIA appreciates the opportunity to make a submission to the Treasury on strengthening protections against unfair contract terms. Download Submission

24

Aug 2021

The Financial Accountability Regime

24 August 2021 AFIA appreciates the opportunity to make a submission to the Treasury on the draft legislation, explanatory materials, and associated documents for the Financial Accountability…

18

Aug 2021

Review of Retail Payments: Consultation Paper

18 August 2021 The Australian payments and financial services regulatory architecture is considered world-class. Australian financial services businesses have been driving change across the fi…

25

Jun 2021

Regulation of the Use of Financial Services Such as Credit Cards and Digital Wallets for Online Gambling in Australia

25 June 2021 AFIA appreciates the opportunity to make a submission to the Parliamentary Joint Committee on Corporations and Financial Services inquiry into the use of financial services such a…

4

Jun 2021

ASIC CP 340 Breach Reporting and Related Obligations

4 June 2021 AFIA appreciates the opportunity to make a submission to the Australian Securities and Investments Commission on CP 340 Breach Reporting and Related Obligations. The new breach re…

24

May 2021

Mobile Payment and Digital Wallet Financial Services

24 May 2021 AFIA has made a submission to the Mobile Payment and Digital Wallet Financial Services Inquiry. The Inquiry’s will focus on the commercial relationships and business models b…

23

Apr 2021

ASIC CP 339 Add On Insurance

23 April 2021 The deferred sales model for add on insurance commences on 1 October 2021. AFIA recommends ways in which ASIC can support industry to implement the deferred sales model. Do…

14

Apr 2021

Breach Reporting Regulations

14 April 2021 AFIA remains concerned with the potential scope of regulatory burden of the new regime and has engaged closely with Treasury throughout the consultation process. Our recommendati…

1

Apr 2021

AFCA Terms of Reference

1 April 2021 AFIA supports Treasury’s review, and recognises it as a timely opportunity to identify where further enhancements can be made to ensure AFCA is operating efficiently and eff…

19

Mar 2021

AUSTRAC Consultation on Phase 1.5 Reforms

19 March 2021 AFIA supports the reforms to the Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) laws, in particular to enable reporting entities to rely on ‘safe harbour&r…

2

Mar 2022

CP 335 Consumer Remediation: Update to Regulatory Guide 256

2 March 2021
AFIA appreciates the opportunity to provide our submission to the Australian Securities and Investments Commission on CP 335 Consumer Remediation: Update to Regulatory Guide…

15

Feb 2021

Deferred Sales Model Exemptions by Class

15 February 2021 AFIA submission to Treasury seeks applications for class-based exemptions from the Deferred Sales Model for marine comprehensive insurance and off-road rider fire and theft in…

12

Feb 2021

Treasury consultation on licensing debt management firms

12 February 2021 AFIA supports the Government’s proposal to licence debt management and credit repair firms. We believe this is the first step in a potential series of activities that wi…

5

Feb 2021

Reference Checking and Information Sharing

5 February 2021 AFIA supports the Government’s commitment to improve reference checking and information sharing protocols in financial institutions (ASIC Protocol). The ASIC Protocol sho…

5

Feb 2021

Payments System Review

5 February 2021 AFIA supports continuing the self-regulatory architecture of the Australian payments system. The payments regulatory architecture should support continued innovation for the be…

3

Feb 2021

2021 Federal Budget

3 February 2021 It is important that the 2021/22 Budget focus on initiatives to further boost and embed our economic recovery to deliver growth above trend. These initiatives include promoting…

24

Nov 2020

Insolvency Reforms to Support Small Business

24 November 2020 AFIA provides a further response to insolvency reforms to support small business. Download

20

Nov 2021

Credit Reform

20 November 2020 AFIA welcomes the opportunity to provide further feedback on the proposed lending framework. As we have outlined previously, AFIA members support the Federal Government’…

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