ASIC’s development of the Regulatory Guide for the new DDOs presents an opportunity to shift the corporate culture of financial firms to ensure customers are at the centre of the entire product lifecycle, and that offending firms are held to account if they sell products that cause harm. The Regulatory Guide must set out a strong, enforceable product governance framework that provides practical guidance and tackles the serious compliance issues in internal controls identified by the Financial System Inquiry (FSI) and the Royal Commission.
We have made a number of recommendations throughout this submission to strengthen the draft DDO Regulatory Guide. Importantly, we have suggested a number of additional product examples be included in the Regulatory Guide, such as buy now pay later, payday loans, consumer leases, point-of-sale lending and funeral expenses policies.
