Consumer Action, Financial Counselling Australia and Financial Rights welcome many of the draft findings and recommendations of the Productivity Commission. We are particularly supportive of findings relating to mortgage brokers, add-on insurance and competition in the payments system. However, we are concerned about the approach taken in relation to reducing barriers to entry and increasing access to data. In our experience, the ‘innovation’ touted by new entrants rarely puts downward pressure on prices or genuinely benefits consumers, but rather takes advantage of regulatory loopholes. Our submission has therefore reiterated the pro-competitive benefits of effective regulation and appropriate barriers to entry, and the risks to consumers when necessary safeguards are absent.