The Consumer Credit Legal Centre (CCLC) supports the regular revision and updating of the Debt Collection Guideline. It is important that the Guideline is updated on a regular basis to account for changes to the law, recent decisions and ongoing improvement in practices and industry standards. The revised draft Guideline is a significant improvement on the existing version, especially the recognition of the need for additional protections for low-income debtors.
CCLC notes that the Guideline is not law, and only represents guidance. In our view, consideration should be given to the Guideline being made into law. The debt collection industry is very large and pervasive, and unfortunately not all debtors subject to debt collection activity have access to EDR. CCLC has ongoing problems with a number of smaller debt collectors who continually breach the Guideline with no consequences. Some of the breaches are very serious, including threatening the consumer that s/he will be reported to the Police. We contend that legislation is required to ensure that all consumers have adequate consumer protection when dealing with debt collectors.
