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Supplementary submission to ASIC Consultation Paper 209: Update to RG 209 Credit Licensing: Responsible lending conduct

26 November 2019

The ABA strongly supports the retention of a principles-based approach to responsible lending through
the legislative provisions contained in the NCCP Act, as well as in relation to relevant regulatory
guidance, including in ASIC’s RG 209 and APRA’s APG 223 and APS 220.

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The interests of the Australian economy will be better served if there is flexibility to innovate and respond to the needs of consumers and businesses, instead of establishing a single government digital identity scheme.

Government can also achieve genuine collaboration with industry without legislation.

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