CCLS joined the Consumer Action Law Centre, Financial Rights Legal Centre, and Financial Counselling Australia, in responding to the Australian Financial Complaints Authority’s (AFCA) draft approach to responsible lending. These organisations have been involved in helping individuals and families deal with disputes related to responsible lending for quite some time, emphasizing the adverse effects of inappropriate credit products on people’s finances and lives.

The submission appreciates the role of AFCA as the primary forum for consumers seeking compensation for harm caused by unaffordable credit. They express support for AFCA’s effort to create an approach to handle disputes concerning responsible lending.

The overall sentiment is in favor of the framework outlined in the Draft Approach, as it aligns with the existing laws and ASIC guidance on responsible lending. The submission acknowledges that there have been inconsistencies in AFCA’s recommendations and determinations in responsible lending disputes, leading to problematic practices and unfair outcomes for consumers. The organizations believe that the Draft Approach addresses many of their concerns regarding these practices.

The submission provides a summary of recommendations, available in Appendix A, and mentions its endorsement of comments made by Redfern Legal Centre, particularly concerning issues related to financial abuse and family or domestic violence.

To read a copy of the submission, click here.