This joint submission by Financial Rights Legal Centre and Consumer Action Law Centre to the Australian Securities and Investments Commission on Consultation Paper CP 339 Implementing the Royal Commission recommendations: The deferred sales model for add-on insurance supports the content of RG 000 and the details provided in CP 339, and the way ASIC intends on interpreting the DSM, considering exemption applications and its proposed approach toward the Customer Information.
However, ASIC is encouraged to provide additional guidance on the interaction between the DSM and other regulatory obligations, in order to set clear expectations for retailers and insurers that are aimed at ensuring they act in accordance with the spirit of all the Royal Commission reforms. While the implementation of the DSM will help reduce pressure selling of junk insurance products, we consider that further action is needed to fully address ongoing mis-selling in car yards.
