The Questions

Please confirm your name below:



Please see the questions for ASICs consultation paper below. Select and expand on your answer as honestly as you can.

D1Q1

Do you consider that continuing credit contracts, when issued to retail clients in the way described in paragraphs 16-22, have resulted in, or will or are likely to result in, significant detriment to retail clients? If so, please provide any relevant evidence which supports your views.

D1Q2

Do you consider that continuing credit contracts, when issued to retail clients in the way described in paragraphs 16-22, have resulted in, or will or are likely to result in, significant detriment other than, or to a greater or lesser extent than, that identified by ASIC? If other or greater detriment, how should the proposed product intervention order be expanded to address this detriment? Please provide any evidence which supports your views.

D1Q3

Are you aware of entities other than Cigno and BHFS that are issuing, or likely to issue, continuing credit contracts in the way described in paragraphs 16-22?

D1Q4

Do you agree with our proposal to make an intervention order by legislative instrument prohibiting credit providers and their associates (including directors of such entities) from issuing continuing credit contracts in circumstances where total fees exceed the maximum permitted under the continuing credit exemption and reg 51 of the National Credit Regulations? Please provide details of why, or why not.

D1Q5

What alternative approaches could ASIC take that would achieve our objectives of preventing the detriment to retail clients identified in this paper?