While designed to give effect to a voluntary code dating from 1991, the regulated financial services sector has changed fundamentally in the intervening three decades, and consumer protection has been strengthened. The voluntary code has been superseded by statutory Codes of Conduct and wide-ranging and strong regulatory powers which are underpinned by intrusive supervision.
As such, our view is that this Bill will not offer borrowers any additional regulatory consumer protections, and instead could have significant unintended consequences to the longer term detriment of all borrowers.