Our submission opens with general comments on the proposed changes, as well as our experience of how banks, superannuation funds and financial institutions have (or have not) applied the Current Guide since we last provided input on its review in 2022. We also provide feedback and recommendations on specific sections of the draft changes, as well as a response to the guiding questions proposed as part of the consultation process. Finally, we provide case studies to illustrate the ongoing challenges that consumers and their advocates continue to face attempting to have their identities verified using non-standard forms of identification, particularly when it comes to identifying people experiencing vulnerable circumstances.
