Consumer Action Law Centre (Consumer Action), Financial Rights Legal Centre (Financial Rights), the Indigenous Consumer Assistance Network Ltd (ICAN), the Victorian Aboriginal Legal Service and WEstjustice strongly support the interventions proposed in CP 355. Since at least 2018, our organisations have assisted many consumers that have suffered significant detriment caused by credit arrangements using the two multi-contract models described in CP 355. We have provided evidence of that detriment to ASIC over this period – in particular, we provided detailed responses to prior ASIC consultations papers CP 316 and CP 330. We continued to see both models described in CP 355 used to issue many loans in 2021.
