Submission on proposed CCCFA amendments
FinCap strongly opposes the removal of credit contract and consumer regulations, especially given the analysis behind this decision has been rushed through.
Officials have had little scope to carefully consider all options and recent evidence.
The rushed approach risks chaos, where some lenders recklessly ignore or do not carefully consider whether loans are unaffordable. Meanwhile, borrowers, financial mentors and regulators would have to navigate through the ambiguity created by the removal of clearly set minimum standards.
Financial mentors need these clear regulated minimum standards to efficiently and effectively challenge lenders for having breached the relevant requirements in the Credit Contracts and Consumer Finance Act.
