1 October 2021
While individual FICA members have provided their own detailed submissions, and these highlight several specific issues relevant to their membership, the purpose of this submission is to outline the key areas of common agreement between FICA members and suggested next steps.
Topics covered include:
– Introduction of civil penalties
– Flexible remedies – Rebuttable presumption
– Flexible remedies – Injunctions
– Existing remedies available under the UCT regime
– Definition of Small Business and Monetary Value of Contracts
– Transitional provisions
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The ABA appreciates the opportunity to contribute to the RBA’s Review of Merchant Payment Costs and Surcharging (Proposals Paper).
The ABA thanks ASIC for the opportunity to comment on its discussion paper on the dynamics between public and private markets.
The ABA welcomes APRA providing clarity on the proposed targeted changes for Higher Education Loan Program (HELP) debt obligations and the constructive approach it is taking on this consultation.