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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.

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 Submission

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…

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’…

9

Nov 2020

Heavy Vehicle National Law

9 November 2020 AFIA supports the harmonisation of state and territory laws through one Heavy Vehicle National Law. Download

12

Oct 2020

Insolvency Reforms to Support Small Business

12 October 2020 AFIA supports the Government’s efforts to respond to the effects of the COVID-19 pandemic on the economy. These reforms are intended to give eligible small businesses the…

19

Aug 2020

ASIC Product Intervention Order: Sale of add-on financial products through caryard Intermediaries - Further Consultation

19 August 2020 AFIA encourages ASIC not to issue its product intervention order on the sale of add-on insurance products through caryard intermediaries. Instead AFIA considers that the sale of…

18

Aug 2020

Review of The Bankruptcy Threshold

18 August 2020 The Commonwealth bankruptcy law must provide a fair and orderly process for dealing with the financial affairs of insolvent individuals while preserving the rights of creditors…

11

Aug 2021

ASIC's Consultation Paper 330: Using the Product Intervention Power: Continuing Credit Contracts

11 August 2020 AFIA focuses on the importance of the appropriate application of ASIC’s proposed use of its product intervention power to continuing credit contracts, ensuring it is appli…

10

Jul 2020

Strengthening Breach Reporting

10 July 2020 AFIA supports Treasury’s amendments to the Strengthening Breach Reporting exposure draft legislation. The implementation of this legislation must balance compliance objectiv…

18

Jun 2020

Litigation Funding and The Regulation of The Class Action Industry

18 June 2020 AFIA supports the extension of the Australian Financial Services Licensing regime to litigation funders. It is also important for economic recovery that the class action system is…

12

Jun 2020

Payment Times Reporting Rules

12 June 2020 AFIA supports the implementation of the Payment Times Reporting Framework to address the issue of late payments from large to small businesses. Download

5

Jun 2021

AFIA Response to Senate Inquiry into Australian Government's response to COVID-19

5 June 2020 AFIA’s response incorporates a number of practical initiatives. This includes initiatives to support a business-led recovery, strengthen consumer and business confidence, sup…

31

May 2021

Consumer Data Right- Energy Sector

31 May 2020 AFIA supports the implementation of the Consumer Data Right (CDR) and the expansion of CDR to the energy sector. We see the continued expansion of CDR into further sectors is criti…

22

May 2020

Inquiry into Future Directions for the Consumer Data Right

22 May 2020 AFIA supports the ongoing development and expansion of the Consumer Data Right (CDR). The expansion of CDR into further sectors will be critical to competition and innovation in t…

16

Apr 2020

Enhancements to Unfair Contract Term Protections

16 April 2020 AFIA supports an effective regulatory regime that provides consumers and small business with a strong level of protection from unfair contract terms (UCTs) in standard form con…

10

Apr 2021

Response to the Select Committee on Financial Technology and Regulatory Technology - COVID 19

10 April 2020 The impact of the COVID-19 crisis on smaller lenders and the fintech sectors was significant. AFIA recommends a number of economic and regulatory initiatives to support these sec…

25

Mar 2020

Mortgage Brokers Best Interests Duty ASIC Regulatory Guide

25 March 2020 AFIA supports the introduction of a best interests duty for mortgage brokers. We recommend ways in which ASIC can support industry to comply with this duty through guidance. Download

17

Feb 2021

The SACC Bill

17 February 2020 AFIA supports the reforms proposed within the National Consumer Credit Protection Amendment (Small Amount Credit Contract and Consumer Lease Reforms) Bill 2019 (No. 2) (the S…

14

Feb 2020

Financial Accountability Regime (FAR)

14 February 2020 AFIA welcomes the opportunity to provide a response to Treasury on the Proposals Paper for Implementing Royal Commission Recommendations 3.9, 4.12, 6.6, 6.7, and 6.8, to exten…

14

Feb 2021

Financial Accountability Regime

14 February 2020 AFIA supports the Government’s commitment to improve risk culture, governance and accountability within financial institutions. This commitment needs to be implemented…

7

Feb 2021

Compensation Scheme of Last Resort

7 February 2020 The Compensation Scheme of Last Resort (CSLR) will allow consumers to be compensated when they have experienced misconduct but are not able to obtain compensation from a financ…

7

Feb 2021

Compensation Scheme of Last Resort

7 February 2020 AFIA supports the Government establishing a Compensation Scheme of Last Resort (CSLR). The CSLR will allow consumers to be compensated when they have experienced misconduct but…

7

Feb 2021

Review of Retail Payments Regulation

7 February 2020 AFIA supports the Reserve Bank of Australia’s approach to self-regulation o the payment sector. In determining if the surcharge framework should be extended to buy now pa…

31

Dec 2020

Response to Senate Select Committee on Fintech and RegTech

31 December 2019 Supporting competition and innovation within the financial services sector is critical to delivering access to and choice in simple and affordable finance to consumers and sma…

17

Nov 2021

ASIC Product Intervention Order: Sale of add-on financial products through caryard Intermediaries

17 November 2019 AFIA encourages ASIC to work closely with industry in issuing its product intervention order on the sale of add-on financial products through caryard intermediaries. Download

11

Oct 2021

Corporations Amendment (Design and Distribution Obligations) Regulations 2019

11 October 2019 The Design and Distribution obligations will require product issuers and distributors to determine the needs of consumers and to design products accordingly. AFIA welcomes the…

12

Sep 2020

Digital Platforms Inquiry - Final Report

12 September 2019 The ACCC’s Digital Platform Inquiry Final report was published on 26 July 2019. The Final Report made recommendations to amend the Privacy Act. These amendments, if im…

20

May 2021

Update to RG209: Credit Licensing: Responsible lending conduct

20 May 2019 AFIA supports ASIC finalising its review and releasing updated regulatory guidance as soon as possible to provide clarity and to assist credit licensees to comply with their respon…

See AFIA Policy Priorities