Submissions
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RBA Review of Merchant Card Payment Costs and Surcharging
On 6 December 2024, AFIA responded to the Reserve Bank of Australia Review of Merchant Card Payment Costs and Surcharging. Our comments build upon our previous submissions to Treasury on reforms to the payments system.
Review of AI and the Australian Consumer Law
On 12 November 2024 , AFIA submitted its response to Treasury’s review of AI in and the Australian Consumer Law (ACL). AFIA’s submission suggests that existing ACL provisions on transparency and fairness provide sufficient coverage for AI-related risks, and recommends that these provisions continue to be appropriately monitored without introducing AI-specific amendments.
AI Mandatory Guardrails
AFIA submitted its response to Industry on 4 October 2024 regarding mandatory guardrails for AI in high-risk settings: proposals paper. The proposal aims to address AI risks across the economy. The Guardrails intend to apply to high-risk settings, with credit applications specifically highlighted in the consultation.
Scams Prevention Framework
On 4 October 2024, AFIA submitted its response to the Treasury on the Scams Prevention Framework. This response builds on the January 2024 consultation regarding a mandatory industry code for scams. The framework’s initial scope includes banks, superannuation, and telecommunications, with mechanisms for expansion to other industries, likely capturing non-bank lenders.
Inquiry Into Australia’s Financial Regulatory Framework and Home Ownership
On 2 October 2024, AFIA made a submission to the Senate Economics References Committee inquiry into Australia’s financial regulatory framework and home ownership.
Consumer Data Right: Consent and Operational Enhancements
On 11 September 2024, AFIA responded to the Consumer Data Right (CDR): Consent and Operational Enhancements Amendments consultation from Treasury.
Independent Review of the Principles of Reciprocity & Data Exchange (PRDE)
On 4 September 2024, AFIA provided feedback on the Independent Review of the Principles of Reciprocity & Data Exchange (PRDE) being undertaken on behalf of Australian Retail Credit Association.
Proposed Updates to Regulatory Guide 274 – Product design and distribution obligations (RG 274)
On 28 August 2024, AFIA responded to the proposed updates by the Australian Securities and Investments Commission to Regulatory Guide 274 – Product design and distribution obligations (RG 274).
Extending the Small Business Responsible Lending Obligations Exemption
On 19 August 2024, AFIA responded to Treasury’s proposed extension of the small business responsible lending obligations exemption. Our response highlights AFIA’s support for the exemption being extended, noting the critical importance of small businesses having access to easily available and appropriately offered credit.
Senate Economics Legislation Committee - BNPL Inquiry
On 28 June 2024, AFIA made a submission to the Senate Economics Legislation Committee’s inquiry into the provisions of the Treasury Laws Amendment (Responsible Buy Now Pay Later and Other Measures) Bill 2024.
BNPL Draft Legislation
On 9 April 2024, AFIA made a submission to Treasury on the draft legislative package to include Buy Now Pay Later (‘BNPL’) products within the National Consumer Credit Protection Act 2009 (Cth)(‘the Credit Act’).
Financial Services Regulatory Framework in relation to financial abuse
In June 2024, AFIA responded to the Parliamentary Joint Committee on Corporations and Financial Services inquiry into ‘Financial Services Regulatory Framework in relation to financial abuse’.
Reforms to Australia's AML/CTF Regime
On 21 June, AFIA responded to the Attorney-General’s Department’s consultation on reforming Australia’s anti-money laundering and counter-terrorism financing (AML/CTF) regime.
Credit Reporting Framework Issues Paper
On 31 May 2024, AFIA responded to the independent statutory review of Australia’s Credit Reporting Framework Issues paper. AFIA acknowledged the importance of a modern and effective credit reporting framework in Australia that is fit for purpose both now and in the future, that caters to all the requirements of the diverse variety of lenders.
Draft of the Corporate Governance Principles and Recommendations 5th Edition
On 8 May 2024, AFIA made a submission to the Australian Securities Exchange Ltd (‘ASX’) on the consultation draft of the 5th Edition of their Corporate Governance Principles and Recommendations.
Exposure Draft ED SR1 Australian Sustainability Reporting Standards – Disclosure of Climate-related Financial Information
On 1 March 2024, AFIA responded to the Exposure Draft ED SR1 Australian Sustainability Reporting Standards – Disclosure of Climate-related Financial Information.
Payments System Modernisation (Regulation Of Payment Service Providers)
On 9 February 2024, AFIA submitted a response to the Payments System Modernisation (Regulation of Payment Service Providers) consultation.
2024-25 Pre-Budget submission
On 29 January 2024, AFIA submitted its pre-budget submission for the fiscal year 2024-25 to the Hon Stephen Jones MP, Assistant Treasurer and Minister for Financial Services.
Climate-related financial disclosure exposure draft legislation
On 9 February 2024, AFIA responded to Treasury’s exposure draft legislation and explanatory materials for climate-related financial disclosure obligations.
Scams – mandatory industry codes
On 29 January 2024, AFIA submitted a response to the Scams – mandatory industry codes consultation.