Joint Consumer Submission in relation to the Changes to Disclosure Requirements under the NCCPA

CCLC and CALC have submitted a joint response to the Treasury’s Discussion Paper regarding proposed changes to the format, content and timing of disclosure requirements under the National Consumer Credit Protection Act 2009 on both credit providers and lessors.  The changes are largely based on empirical research into pre-contractual disclosure that was commissioned by the Senate.  The proposals are framed by the following policy objectives:

1. Making changes that will improve consumer understanding.
2. Highlighting key pricing information in a new Table called the Financial Summary Table.
3. Repealing existing unnecessary disclosure requirements.

Our joint submission largely supported the proposed changes that were a reflection of the empirical research presented in the recently released Uniquest Report.

Our submission includes suggested amendments to each of the following product-specific disclosure requirements:

1. Home Loans
2. Lender’s Mortgage Insurance
3. Credit Cards
4. Personal Loans (including Car Loans)
5. Reverse Mortgages
6. Consumer Leases
7. Small Amount Loans (ie Payday Loans)