Consumer’s Federation of Australia Joint Consumer Submission: Australian Finance Industry Association (AFIA) Buy Now Pay Later Code of Practice and AFIA Terms of Reference for the BNPL Code Compliance Committee

We note AFIA’s intention that the BNPL Code will reach ‘above and beyond the law’.10 We
embrace this goal. The goal is in line with the ASIC’s Regulatory Guide 183 ‘Approval of
financial services sector codes of conduct‘, which we discuss below. AFIA’s BNPL members
will be better able to reach this goal if consumers are provided with basic protections under
the NCCPA, then the BNPL Code can focus on additional commitments.