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Chapter 2
Hardship variation and enforcement of credit contracts
2.1
The National Credit Code currently provides for borrowers to seek
variations of credit contracts in circumstances of hardship.[1] Under the existing
legislation, borrowers with credit contracts for less than $500 000 may apply
for hardship variations if they are unable to meet their repayment obligations
due to 'illness, unemployment or other reasonable cause'. There are only three
kinds of variations available, namely:
- extending the period of the contract and reducing the amount of
each payment due under the contract accordingly (without a change being made to
the annual percentage rate or rates);
- postponing for a specified period the dates on which payments are
due under the contract (without a change being made to the annual percentage
rate or rates); or
- extending the period of the contract and postponing for a
specified period the dates on which payments are due under the contract
(without a change being made to the annual percentage rate or rates).
2.2
The borrower must include information that demonstrates that the
borrower could meet the changed repayment obligations.
2.3
Within 21 days of receiving the application, the credit provider must
send written notice to the borrower either agreeing to the proposed change or
informing the borrower of the reasons why the application has been refused and
providing the borrower details of an approved external dispute resolution
scheme. Failure to do so is a strict liability offence with a penalty of 30
penalty units.[2]
2.4
Credit providers are not required to respond to hardship variation
requests before commencing proceedings to enforce the debt.[3]
2.5
The Enhancements Bill would extend the circumstances in which hardship
variations may be sought and reduce the procedural requirements on borrowers. As
outlined in the Explanatory Memorandum, the following amendments are proposed.
- All borrowers may apply for hardship variations, regardless of
the value of the credit contract.
- The hardship notice may be made orally or in writing.
- While called a ‘hardship notice’, the Bill does not expressly
state that in order to apply for the contract to be varied the borrower's
capacity to repay must be affected by hardship. The application therefore does
not have to contain reasons why the borrower is unable to meet the repayment
obligations.
- The Bill also does not impose limits to the form of hardship
variation that the borrower may request.
- The borrower is not required to demonstrate that he or she could
meet the changed repayment obligations.
- Within 21 days of receiving the notice a credit provider must
either notify the borrower that they are prepared to negotiate a contract
variation or are refusing the request. If refusing the request, the credit
provider must provide reasons for the refusal and details of an approved
dispute resolution scheme.[4]
2.6
The credit provider would commit an offence by failing to either notify
the borrower within the 21 day timeframe that they are prepared to vary the
contract as requested or by refusing the request to negotiate a contract
variation. If providing notice of the credit provider's refusal to negotiate,
the credit provider would still commit an offence if the notice does not
provide reasons for refusing to negotiate, details of an approved external
dispute resolution scheme of which the credit provider is a member and details
of the borrower's rights under that scheme. The offence is a strict liability
offence with a maximum penalty of 30 penalty units.
2.7
The Bill would also introduce clause 89A, which would alter the
requirements for seeking to enforce credit contracts in response to borrower
default. Under the revised regulatory framework, creditors would be required to
respond to hardship notices before seeking to enforce the credit contract. If a
hardship notice is given prior to or after the creditor has issued a default
notice, the creditor must not commence enforcement proceedings until 14 days
after responding to the hardship application. The credit provider would commit
an offence if initiating enforcement proceedings in contravention of these
restrictions. The offence would also be a strict liability offence and would
expose the credit provider to a maximum penalty of 50 penalty units.
2.8
Proposed clause 94 would also provide borrowers the right to request or
demand credit providers delay proposed enforcement proceedings for 14 days.
2.9
The new lending environment would commence on 1 July 2012,[5]
approximately two years since the National Credit Code, and the hardship
variation provisions it currently contains, came into operation.[6]
The Explanatory Memorandum clarifies the intention underlying the proposed
amendment, stating that the reforms will 'make it easier for debtors to apply
for hardship variations, by making the procedures more flexible.'[7]
2.10
Details of the background to, and the rational for, the proposed changes
were provided in Treasury's July 2010 Green Paper. The paper explains
that the existing provisions in the National Credit Code replicate the hardship
provisions in state and territory consumer credit regulations but do not
address issues with their operation. The paper argues that the Council of
Australian Governments (COAG) envisioned that the issues would be the subject
of further consultation and legislative proposals progressed under phase two of
the national consumer credit reforms:
As part of the transitional arrangements agreed between the
Commonwealth, State and Territory Governments and industry, minimal changes
were made in replicating the UCCC [Uniform Consumer Credit Code] as the
National Credit Code on the basis that these issues would be given further
consideration during Phase Two.[8]
2.11
The paper informs readers that the identified issues included whether
further enhancements are required for the hardship variation provisions and the
enforcement provisions.[9]
The paper goes on to provide the following rationale for amending the framework
for hardship variations and enforcement proceedings.
The limited range of variations that can be requested on the
basis of financial hardship may lack sufficient flexibility to enable the most
mutually beneficial outcomes for both lenders and consumers. Furthermore,
having a monetary threshold above which a consumer does not have a right to
request a variation applies an arbitrary limitation. Neither of these
restrictions are entrenched in the industry codes of conduct.
In most situations it is likely to be advantageous to both
lenders and consumers to keep a credit contract out of default, provided that
the consumer can reasonably be expected to meet their commitments following a
variation and the lender is able to receive repayment within a reasonable
timeframe.[10]
2.12
The Regulation Impact Statement provides further insight into identified
problems with the regulatory framework as it currently stands. The statement
provides an overview of research conducted in 2009 by the Australian Securities
and Investments Commission (ASIC) into the hardship practices of 15 major lenders.
The ASIC research draws the following conclusions about the availability of
hardship variations.
One lender would only consider an application made in
accordance with the statutory requirements, and that otherwise it would not
offer any assistance. All the other lenders did not differentiate in their
responses.
Lenders preferred to provide a similar response irrespective
of the borrower's situation; typically this was short term assistance such as a
three month payment moratorium. This response did not require an assessment of
the consumer's circumstances and needs and then varying the contract to match
those needs.
Lenders generally have a far wider range of options for
responding to hardship than those set out in the Code, but in practice tend to
provide a much narrower range of options.[11]
2.13
The statement draws on anecdotal evidence provided by the Financial
Ombudsman Service and the Credit Ombudsman Service, as well as the ASIC
research, to make the following conclusions about the utility of the hardship
variation schemes established under the state and territory consumer credit
legislation:
...borrowers only have a right to seek a variation to address
short-term hardship on relatively narrow grounds, and where their request conforms
to precise legal requirements. This creates a risk of two distinct problems for
borrowers:
- the
lender may refuse to consider a variation of their contract because the
borrower's request did not conform to the requirements under the Code; or
- lenders
may only provide a variation that is one of the three options set out in the
Code, when a different response would more effectively address the borrower's
situation.
In both cases the consequence for the borrower is the same,
namely that they may default under their credit contract and face enforcement
action when, in some situations, this could have been avoided.
There is evidence from a number of different sources that
some lenders are not properly meeting the obligations in their voluntary code
in relation to hardship, and that they are only complying with the requirements
in the Credit Act. They therefore have practices which mean they do not actively
seek to resolve, in a broader way, the position of borrowers who are in
financial hardship.[12]
Support for the new approach to hardship variations and enforcement of
credit contracts
2.14
On the basis of evidence before the committee, it appeared that the
Enhancements Bill generally addresses concerns of consumer advocates with the
existing legislative provisions governing consumers' access to hardship
variations.[13]
The views of Anglicare Victoria seemed representative of the perspective of the
consumer advocates who participated in the inquiry:
Anglicare Victoria supports the provisions...that protect
debtors in cases of hardship and make it easier to apply for hardship
variations, by making procedures more flexible.[14]
2.15
Good Shepherd Youth and Family Services provided the following comments
in support of the Bill:
We support the changes which place greater onus on the credit
provider to inform consumers of their rights when seeking hardship protections.
Often people who seek these provisions need to ask for those explicitly when
dealing directly with their credit provider. Without the intervention of a
financial counsellor or other advocates, many people are not aware of hardship
provisions or able to access them. Even in the instances where a financial
counsellor is able to assist, the burden of proof can make accessing these
provisions difficult if not impossible. Our financial counsellors often find it
challenging to support people experiencing hardship, particularly when clients
are maintaining their debt obligations at the expense of other needs.[15]
2.16
Good Shepherd Youth and Family Services also approved the proposed
enforcement procedures, arguing that these address a deficiency in existing
legislation and would therefore increase protection for vulnerable consumers:
We understand there is a need to allow sufficient time for
credit providers to assess claims and develop means of addressing these.
However, that time in the interim can be critical to those being affected by
hardship. We believe section 89A addresses these concerns by prohibiting credit
providers from taking collection action while claims for hardship are being
assessed.[16]
2.17
It appeared that the proposed changes have in-principle support from
sectors within the credit provider industry. However, as the extract from the
submission from the ANZ demonstrates, while there is support for the policy
objective there were strong concerns with details of the proposal as drafted:
We support the Government's intention to make it as easy as
possible for customers to apply for hardship assistance. However, there are a
number of practice issues with this section.[17]
Concerns with draft provisions relating to hardship variations
2.18
With the exception of the submission from the Mortgage and Finance
Association of Australia, submissions received from industry were consistent in
the view that the provisions as drafted will present substantial practical
difficulties for credit providers.
2.19
The Mortgage and Finance Association of Australia argued that the
provisions uphold the principle of supporting borrowers, which is a feature of
the association's code of practice:
MFAA has long supported the need to support borrowers in
hardship. Our Code of Practice has included, for some years, hardship
provisions. That being the case we support the new section 72(1) which allows
borrowers to give lenders a 'hardship notice' orally or in writing, if unable
to meet their obligations, without the need to specify the nature of the
hardship in detail.[18]
2.20
In contrast, the committee's attention was repeatedly drawn to industry
concerns that the revised hardship variation procedures would not be feasible
for industry nor provide certainty for the borrower. Concerns were raised with
the following aspects of the proposal.
- Removing the requirement for the borrower to demonstrate they
could reasonably be expected to meet the revised repayment obligations.
- Allowing hardship variation notices to be given verbally.
- Extending the hardship variation regulations to apply to credit
contracts valued over $500 000.
No requirement for borrowers to
demonstrate capacity to meet the varied repayment requirements
2.21
As noted, the amendments to subsection 72(1) contemplate that hardship
applications would not be required to contain information that demonstrates
that the borrower could meet the changed repayment obligations. Evidence before
the committee indicated that the absence of this requirement is a serious
concern to several key industry stakeholders. The Credit Ombudsman Service
argued that:
...it would be extremely useful, if not critical, for the
proposed new section 72(1) to retain in some way the implicit requirement
in the existing section 72(1) that the credit contract should be varied where
the borrower reasonably expected to meet their obligations under the contract
if the contract was changed in a particular way.[19]
2.22
Concerns were also expressed in more emphatic terms, with the committee being
advised that, in the absence of a requirement for borrowers to demonstrate
ability to meet the revised repayment obligations, the hardship variation system
would be 'unworkable'. As GE Capital argued:
...we do not believe that variation is warranted if
there is no reasonable expectation that the proposed variation to the contract
will enable a debtor to meet his or her obligations that the proposed variation
to the contract will enable a debtor to meet his or her obligations under the
credit contract. This is the key to whether a variation to the credit contract
should be made. The loss of this...key component will render section 72
unworkable.[20]
2.23
GE Capital stressed that credit providers 'must be able to decline to vary
a credit contract on hardship grounds where there is no reasonable expectation
that the proposed variation to the contract will enable a debtor to meet his or
her obligations under the credit contract.'[21]
2.24
Abacus – Australian Mutuals also considered the provisions to be
unworkable. The committee was informed that the provisions as drafted will
limit, rather than increase, borrowers' access to hardship variations in
legitimate circumstances. It was argued that accordingly the provisions would
increase the burden on borrowers and credit providers:
The problem in practice with the procedure proposed in the
Bill would be that, in many cases, the debtor—although prompted to do so by the
credit provider—will not in fact provide the information needed, either at all
or within a reasonable time, for an assessment of whether hardship relief can
be offered to be made. In such cases the credit provider, in order not to
breach the provision, will have little alternative but to refuse to negotiate a
hardship change even if it would have been prepared to do so had it been in
possession of the information needed to make an assessment.
This appears to be a perverse and unintended outcome. We
would emphasise, however, that it is not a merely theoretical one.[22]
2.25
ANZ also noted the potential for the provisions to increase the
administrative burden on borrowers and credit providers:
On a practical level, this will mean that debtors can notify
credit providers of their inability to pay without there being any likelihood
that they can discharge their repayment obligations in the short to medium
term. It is ANZ’s view that this will also substantially increase customer
correspondence without deriving consumer benefit.[23]
2.26
The committee was further informed that the borrower's capacity to meet
the varied repayment obligations is the threshold test currently applied by the
court in determining credit contract variation disputes. As the Credit
Ombudsman Service stated:
[w]e whole-heartedly support the changes proposed to be made
by Part 1 (Protection of debtor in cases of hardship), but urge the Committee
to recommend a change to the proposed new section 72(1)...There would otherwise
be little or no guidance for a Court or an EDR scheme to determine if a credit
contract should be varied.[24]
2.27
Having recommended the inclusion of a requirement for borrowers to
demonstrate capacity to repay under the amended contract, submitters also
recommended further procedural requirements to remove any uncertainty. First
Stop Money submitted that borrowers should be required to provide 'documentary
evidence within 30 days of requesting hardship.'[25]
2.28
An alternative approach was recommended by the Australian Bankers'
Association and Abacus – Australian Mutuals, which submitted that the 21 day
timeframe should not commence before the credit provider receives sufficient
information to assess the application.[26]
As Abacus – Australian Mutuals stated:
...the 21 day period that the credit provider has to give the
debtor a notice in response to a hardship notice in s72(2) would only commence
from the day the debtor has provided the credit provider with the financial
information it reasonably requests in order to assess the debtor's financial position.[27]
2.29
ANZ supported this proposal, stating that this was of particular
importance in the context of a breakdown in the relationship of joint
borrowers:
The trigger of the 21 day response time commencing
immediately upon verbal notification from a customer, rather than once
sufficient information has been provided to enable an assessment to be made, is
of particular concern in the context of a joint mortgage and where there has
been a breakdown in the relationship between the borrowers. In order to make an
assessment of whether to negotiate, a credit provider will need information for
all parties to the loan. In the case of a joint loan, the refusal of one party
to provide information can impede our ability to assess both or one of the
borrowers for hardship assistance. If a credit provider simply declined to
negotiate a change on the basis of not having sufficient information, it is
likely to result in increased complaints to external dispute resolution
schemes.[28]
2.30
The Australian Finance Conference, whose comments in general also
referred to the hardship variations proposed to apply to credit contracts under
Schedule 3 of the Enhancements Bill, argued that this measure would be
consistent with ASIC advice regarding the existing hardship provisions under
the National Credit Code:
We also note the compliance difficulty the wording of s. 72
currently raises for lenders and the ASIC response (October 2010) to assist. In
short, to address concerns expressed by lenders in relation to the timeframe
for decision where insufficient information has been provided by the borrower,
ASIC clarified its position in Information Sheet 105: Dealing with Consumers
& Credit. In ASIC’s view the 21 day period commences only after the borrower
makes an application with sufficient information to allow the credit provider
to make a final decision. Where insufficient, the credit provider will need to
identify what further information is required and advise the borrower as soon
as practicable. Until that information is provided, ASIC will not regard an
application as having been made and the 21 days will not have commenced.[29]
2.31
An additional step was also proposed to promote best-practice by credit
providers. Abacus – Australian Mutuals submitted that the Bill 'might also be
amended to oblige the credit provider to seek any financial information it
requires as soon as possible after receiving the hardship notice.'[30]
Removing the requirement for
hardship notices to be provided in writing
2.32
It was a view expressed across industry submissions that informal, that
is, verbal applications would lead to misunderstandings between the credit
provider and the borrower. It was further argued that this would therefore
thwart the intention to increase borrowers' access to hardship variations. As
the ANZ stated:
The fact that a debtor is only required to give a hardship ‘notice’ rather than make an ‘application’ is too vague and uncertain and
potentially triggers the need to issue formal correspondence in too many cases.
In practice, this would make it difficult for credit
providers to ascertain whether their obligations under s. 72 have been
triggered. For example, there may be instances where a debtor says that they ‘notified’ branch staff or a call centre operator of difficulty in making
repayments, but this may have been expressed in such a way or interpreted as
something other than notification, for example, a complaint.[31]
2.33
The ANZ also submitted that verbal notifications will remove existing flexibility
to address borrowers' needs:
The proposed amendments remove flexibility in the way ANZ can
offer temporary repayment arrangements to assist customers to deal with short
term financial instability.
ANZ will often offer very short term relief arrangements for
customers who are experiencing a temporary difficulty in meeting repayments. This
difficulty may be due to an unexpected expense incurred by the customer that,
while causing some financial instability in the very short term (meaning the
customer may miss one or two repayments to their loan), is not indicative of
financial hardship. In these cases, once the cause of the short-term difficulty
is explained by the customer and ANZ is comfortable the issue is temporary, ANZ
will often be able to offer an arrangement over the telephone, with a minimum
of ‘red tape’ for the consumer.
However under the current proposed amendments, these
scenarios will need to be treated in the same way as a financial hardship
situation, requiring the issue of formal correspondence within 21 days, without
any added perceived consumer benefit. We expect the added administrative burden
in this area of our customer assistance team (mainly involving the preparation
and dispatch of confirmation letters) will cause delays in responding to
customers seeking short-term informal relief arrangements.[32]
2.34
This view was shared by the Australian Bankers' Association, which
outlined the following scenario:
...a customer may advise the credit provider of their
inability to meet one of their credit card repayments on the due date or make
their monthly home loan repayment on time but will do so in two weeks’ time and
could request an extension of time to make the repayment. Under the current
law, such a notification could be solved immediately through an agreed
arrangement between the credit provider and customer without a formal process
being needed.
Notwithstanding the flexibility of the current law, the Bill
proposes that such a notification would trigger the formal hardship process,
thereby increasing the number of hardship notifications received by credit
providers and an associated increase in the resourcing requirements of credit
providers. A credit provider would have to issue a section 72(2)(a) notice
agreeing to negotiate and then a section 73 notice setting out a change to the
contract if it is agreed to. This would delay the commencement of the
arrangement to the detriment of the customer.
In these situations this prescriptive process would be
completely unnecessary and confusing for the customer.[33]
2.35
Noting that failing to respond within the 21 day timeframe is an offence,
the Australian Bankers' Association argued that verbal applications would
entail significant risks for industry:
...if someone rings up and is unclear about what it is they
are actually seeking then the whole process of getting a better understanding
of it is very awkward. It could be just a chance comment in a branch or it
could be a chance comment over a telephone that someone does not recognise is
someone saying, 'I don't think I'm going to meet my obligations under the
credit contract.' If that is not acted upon, inadvertently that triggers a
21-day notice, with a criminal penalty at the end of it if you do not comply.[34]
2.36
The Australian Finance Conference also noted the offence provision,
arguing that it should be removed:
The proposed reforms are designed to facilitate flexibility
by the consumer with the process of soliciting variation on the basis of
hardship. Again, the AFC supports this. However, for it to be a mutually
beneficial outcome in line with the Government’s objective, similar flexibility
needs to be adopted for the compliance obligations of the lender. In particular,
AFC recommends that strict timeframes should be replaced with concepts like
“within a reasonable time;” and offence provisions should be removed.
This would have the benefit of allowing lenders to minimise
regulatory risk while working with customers on a specific or targeted basis
with the primary aim of assisting the customer to overcome their short-term
financial difficulty while continuing to meet their contractual obligations.[35]
2.37
The committee heard that, to promote best-practice, the option for hardship
applications to be made verbally should be removed.[36]
Extending the hardship variation
regulations to apply to credit contracts valued over $500 000
2.38
Aussie submitted that hardship variations are unnecessary for loans over
$500 000:
It is important that lenders have commercial certainty on
large investment loans. Borrowers already have sufficient protection under new
laws in any event without the need to provide defaulting borrowers with
additional mechanisms to further delay the recovery process.[37]
2.39
Accordingly, Aussie recommended the $500 000 cap be retained, or, as an alternative,
be only available for loans over $500 000 that are secured by the borrower's
principle place of residence rather than residential investment property.[38]
Concerns with provisions relating to enforcement of credit contracts
2.40
Concerns were raised with clauses 89A and 94, which would alter the
requirements for seeking to enforce credit contracts in response to borrower
default and give borrowers the right to request or demand a 14 day delay in the
commencement of enforcement proceedings. The Australian Bankers' Association
argued that the clause was unduly complex, and could be used by the borrower to
stall enforcement proceedings.[39]
The Association recommended the Bill be amended to make it clear that a
borrower may only seek to delay enforcement proceedings once under clause 94:
If this provision is retained, it is necessary for the Bill
to clarify that a customer can only delay the enforcement proceedings once on
this ground. This will ensure that an abuse of process does not take place on
the part of the customer.[40]
2.41
Aussie also questioned whether the postponement could delay dispute
resolution procedures, noting that any delay in dispute resolution once the
matter has been referred to an approved dispute resolution provider could
entail significant costs for both the borrower and credit provider.[41]
2.42
The Australian Finance Conference did not support the introduction of
clause 89A, arguing that it was unnecessary:
...the current postponement provisions and financiers’ practices of trying to proactively manage customers who are in difficulty mean
there is ample opportunity for customers to seek assistance before proceedings
are commenced...
We are advised by our Members that it would be operationally
extremely difficult to implement a process to comply with its requirements.
They also submit that the customer may be disadvantaged through the process; an
outcome that should be avoided.[42]
Committee view
2.43
The committee endorses the intention to establish a hardship variation
scheme that provides appropriate support to vulnerable consumers while
providing commercial certainty. Hardship variations are an essential part of an
effective credit market, ensuring consumers can continue to participate despite
unanticipated financial distress. The provisions also allow industry to retain
clients despite unforseen changes in the clients' financial circumstances. This
in turn can build client loyalty.
2.44
However, the committee considers that impractical procedures would
undermine the intention to strengthen vulnerable consumers' access to hardship
variations. The committee notes industry concerns that the hardship scheme
proposed may not be practical due to the absence of a requirement on borrowers
to provide all necessary documentation regarding the kind of hardship variation
they are seeking and their capacity to repay. This appeared to be a particular
concern in relation to verbal applications.
2.45
The committee considers that the proposal to allow hardship applications
to be made verbally tips the balance too far in the direction of the consumer.
It is not at all clear to the committee that the proposal is practical and it
would most likely reduce the flexibility that is currently in the system which
allows providers to vary contracts in the face of short term financial need on
behalf of the consumers.
2.46
Evidence that the revised scheme may not be practical for industry is
all the more concerning as the offence for failing to respond to the consumer's
application in one of the two required way is an offence of strict liability.
It is therefore all the more essential for the requirements on credit providers
to be clear and practical to implement.
2.47
For this reason, the committee recommends that clause 72 be amended to
require borrowers to provide reasonable information to assist credit providers
to assess their hardship application. The clause should be further amended to
provide credit providers reasonable opportunity to request this information
where it is not initially provided.
2.48
The committee notes the concerns raised by Good Shepherd Youth and
Family Services that the threshold to demonstrate hardship and capacity to
repay currently applied by credit providers can be too high. The committee
draws this concern to the Government's and industry's attention, and encourages
industry to consider how Codes of Conduct can practically respond to the
challenges that borrowers may face in providing documentation and other
evidence required to establish hardship and the borrower's capacity to repay.
2.49
The committee considers that the hardship variation scheme would be
strengthened through greater consumer awareness and understanding of the
availability of hardship variations and their associated rights and
obligations. To this end, the committee recommends Government work with
industry to develop a plain English, user-friendly information pack outlining
the application of the hardship variation scheme and the steps which borrowers
can take to vary their repayment obligations. To further assist vulnerable
consumers, the information pack could provide a link to the details of
financial counselling services as provided on ASIC's MoneySmart website.
2.50
The committee also notes concerns with the operation of clause 89A and
clause 94, particularly the Australian Bankers' Association's view that
the clauses may result in a cycle of default notices and postponement
applications that would prevent credit providers from enforcing the credit
contract. On the basis of information provided to the committee it is not clear
that the provisions as drafted would allow for this scenario. However, the
committee brings to Government's attention the concerns with the effect of the
provisions as drafted.
Recommendation 2
2.51 The committee recommends that clause 72 be amended to require borrowers
to provide reasonable information to assist credit providers to assess their
application and to give credit providers reasonable opportunity to seek this
information from the borrower where it is not initially provided.
Recommendation 3
2.52
The committee recommends that 'orally' be removed from subclause 72(1),
to require hardship applications to be made in writing.
Recommendation 4
2.53 The committee recommends that Government work with industry stakeholders
to develop a plain English, user-friendly information pack about borrowers'
rights and obligations in relation to hardship variations. The Government and
industry should consider including a link to the information on the MoneySmart
website about financial counselling assistance. Industry should be required to provide
a copy of this information pack on their websites and at customer service
centres.
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