National Credit Protection Amendment Submission

ACCI supports the draft amendments proposed in the National Consumer Credit Protection
Amendment (Supporting Economic Recovery) Bill 2020. The proposed amendments will provide
greater flexibility for lenders while maintaining strong consumer protections for borrowers. The
effectiveness of the primary financial dispute resolution body, the Australian Financial Complaints
Authority (AFCA) has not, but should be, considered as part of maintaining consumer protections.

The proposed Bill will also remove regulatory duplication for ADI lenders and enhance competition.
The responsible lending obligations (RLO’s) are no longer fit for purpose and the proposed risk-based
approach should provide lenders with greater flexibility in exercising their rights to credit
provision. However, it is not determined the full extent to which these reforms will increase the
volume of lending to small business or the extent to which lending will be based on more competitive
terms. APRA guidance and clarity is needed to the benefit of lenders and borrowers.