Financial Rights’ biggest concern with the proposed draft Regulation is that this review of the legislation is a missed opportunity to adequately protect consumers, especially vulnerable consumers. The primary objective of the proposed regulation appears to relate only to preventing the sale of stolen goods, even though the NSW Department of Customer Service claims it should also be to protect consumers who enter into pawn agreements. There is almost no attention given to preventing other unscrupulous business practices towards consumers that have pawned, and hope to reclaim their own goods. Consumer protection improvements in the 2020 draft Regulation are negligible to non-existent. During the current unprecedented economic downturn, the most vulnerable people in our community will be turning to non-traditional forms of credit when formal Government support streams are closed. Now is the time to ensure those people are not exploited by unscrupulous pawnbrokers and second-hand dealers