Joint Consumer Submission to AFSA on debt agreement marketing (IGPG 1)

This was a joint submission with Consumer Action Law Centre and Financial Counselling Australia.

There have been a number of positive amendments to the Guideline, particularly in relation to
third parties. However, we have suggested a number of amendments to further strengthen the
Guideline below, including recommendations to:

• ensure the proposed amendments are expressed in plain English;
• provide further guidance on what specifically amounts to an ‘unsuitable debtor’;
• provide additional practical examples;
• clarify that telephone conversations are a form of ‘advertising and marketing’;
• specify that the term ‘alternative to bankruptcy’ is likely to be misleading;
• address the appropriateness of targeting consumers who have recently have default
  judgments entered against them.