Senator David Pocock's additional comments
1.1While total scam losses in Australia appear to be declining, the number of scams is increasing. In 2023 there was an 18.3% increase in the number of scam reports. Collectively, Australians lost $2.74 billion to scammers in 2023 - equivalent to 1% of our GDP. In terms of financial losses, investment scams continued to cause the most harm ($1.3 billion), followed by remote access scams ($256 million) and romance scams ($201.1 million).[1]
1.2Australia’s regulatory environment for preventing scams and protecting consumers from them is less robust than other comparable nations.
1.3In a review released in August last year the Australian Securities and Investments Commission (ASIC) said, ‘Like the four major banks we reported on last year, the 15 banks in this latest report also demonstrated a less mature approach to scams strategy and governance than we expected’.[2]ASIC noted in this review that ‘those [15] banks detected and stopped just 19% of scam transactions by value. They found more than 20,000 of their customers footed the bill for 96% of the money scammers stole last financial year.
1.4This must change.
1.5And these losses have been incurred is the context of the major banks reporting a combined profit after tax of $29.9 billion in 2024. Telstra made a net profit after tax of $1.8bn in the 2024 financial year, while Meta Platforms generated a revenue of over $164 billion U.S. dollars.
1.6Not only must this new framework help prevent scams, including by incentivising regulated entities to invest more in detection and prevention, it must also ensure victims of scams are far better compensated.
1.7The government deserves acknowledgement for the consultation they have undertaken on this framework which included the release of a Scams – Mandatory Industry Codes Consultation paper in November 2023, release of exposure draft legislation in September 2024 and culminated in the final legislation being tabled on 7 November 2024. It should be noted however that some stakeholder cohorts claim the government engaged more closely with the banking sector than others.
1.8I also thank the Minister for his engagement with the crossbench in both the House of Representatives and the Senate in briefing us on this bill and providing an opportunity to voice the concerns that have been raised with us.
1.9The above remarks notwithstanding, I am worried that the final legislative framework brought forward by the Government does not strike the right balance between the needs of Scams Prevention Framework (SPF) regulated entities and consumers and that it does not provide sufficiently for compensation. These concerns have been highlighted by consumer groups. SPF regulated entities have, in addition, put forward a number of suggested amendments to the bill. In light of the evidence tendered to the Committee, I am concerned that the government, having left introduction of this legislation to the end of the parliamentary term, is unwilling to properly consider good faith amendments to the bill for fear of delaying its passage prior to the upcoming election.
1.10Another challenge with the proposed Framework that has been raised by consumer groups and potential SPF regulated entities alike is that much of the actual compliance and obligation detail will be contained in Industry Codes that are to be developed separately and subsequent to the framework the bill establishes.
1.11I note four members of the crossbench have already moved amendments to this bill in the lower house.
1.12The Member for Wentworth, Ms Allegra Spender MP, has moved an amendment to require the regulated entity to publish information about scams detected, reported and responded to. The Consumer Organisations jointly support this amendment.
1.13The Member for Mackellar Dr Sophie Scamps MP has moved an amendment that seeks to require regulated entities to better consider the needs of vulnerable consumers. The Consumer Organisations jointly support this amendment.
1.14The Member for Kooyong Dr Monique Ryan MP has moved a second reading amendment highlighting some of the concerns consumer groups have raised with the bill as drafted.
1.15The Member for Warringah Zali Steggall OAM MO has also moved an amendment which I will address in the recommendations that form part of my additional comments.
1.16There is broad support from stakeholders including regulators, regulated entities and consumer groups, for a strong scams prevention framework. There is also support for the government’s ‘ecosystem’ approach.
1.17There is however significant divergence among stakeholder cohorts concerning proposed amendments to the bill.
1.18One constant however is the need to provide more certainty, for both consumers and regulated entities.
1.19The Australian Competition & Consumer Commission (ACCC) sums up the sentiment my community has expressed when it says ‘The ACCC has long advocated for consumers to be at the heart of any legislative framework designed to combat scams’.[3]
1.20Regulating the prevention of and protection from scams, pits vested interests against community interests. The bill needs to strike the appropriate balance between regulation and protection. There is a need to incentivise hugely profitable private companies to invest in scam detection and prevention technologies.
1.21Optus cites a standout example of this in a partnership with Westpac to ‘develop SafeCall, which allows Westpac customers to receive calls via the app that are Westpac branded, verified by Optus and displays a reason for the call. This program provides customers more certainty in the legitimacy of the call, at a time when bank impersonation scams are among the most common scam types impacting Australian customers.’[4]
1.22Australia’s scam prevention regulatory environment should encourage more investments and partnerships like this one to effectively protect consumers from increasingly sophisticated scams.
1.23What the government is proposing is unlike any other regulatory framework currently in operation. As the Telecommunications Industry Ombudsman notes ‘The approach proposed in the SPF Bill is untested in any other jurisdiction. While the effort to develop a world-first solution to the scourge of scams is to be applauded, the SPF Bill does not provide certainty about IDR pathways, how liability will be apportioned across entities, or when a consumer can access EDR. Customer journey mapping prepared by consumer groups in response to an Exposure Draft of the SPF Bill suggests that a scam complaint may take up to two years to resolve.’[5]
1.24This timeframe is clearly unacceptable, especially in cases where victims have lost life-altering amounts of money to scams.
1.25Concerns have been raised by the Scrutiny of Delegated Legislation Committee, of which I am also a member, about how much detail has been left to delegated legislation, especially concerning the codes and the obligations on regulated entities.
1.26These concerns have been echoed by regulators, consumer groups and regulated entities, albeit for different reasons.
1.27On the one hand, regulators and consumer groups call for more clarity and detail in the SPF Bill:
The ACCC considers that the inclusion of more detailed provisions in the primary legislation could assist in harmonising requirements across sectors and ensure regulated entities clearly understand their obligations. For example, we would welcome detailed provisions in the primary legislation about what may constitute ‘reasonable steps’ or a ‘reasonable time’.[6]
1.28The Telecommunications Industry Ombudsman emphasises this point also saying ‘The SPF must provide for a consumer-centric approach to providing consumer redress. Fundamental issues have been left to subordinate instruments, without adequate stakeholder consultation to ensure consumers will be able to navigate the SPF’s multi-party approach to scam disputes in a timely and fair manner.’[7]
1.29On the other hand, SPF regulated entities and their representatives call for obligations to be devolved out of the Framework and into the Industry Codes.
1.30Digital Industry Group Inc. (DIGI), the peak body representing the digital industry, is concerned that the Framework and the Codes will create two sets of obligations on regulated entitled and have argued for the removal of Division 2 of the bill, with any and all obligations to be contained in the industry codes (which have not yet been developed).[8]
1.31Like DIGI, Communications Alliance wants as much detail as possible delegated to the sector specific codes. They, like DIGI, raise concerns about potential overlapping regulation from the ACCC (general regulator), ACMA (sector regulator), AFCA (Australian Financial Complaints Authority - external dispute resolution) and civil litigation.
1.32Another SPF regulated entity, Optus ‘submits that the SPF Bill is unnecessarily complex due to it addressing many issues of detail and process which would be better dealt with via various industry codes. This has resulted in an unworkable and ineffective Bill that risks not achieving many of the goals which we all support.’[9]
1.33Similarly, the Insurance Council of Australia, representing a sector that has been flagged as potential for inclusion as a designated sector notes, ‘Further, it will be important to ensure that the sector-specific Codes do not duplicate existing regulatory requirements, such as reporting obligations or the FAR noted above, and align appropriately with other relevant industry codes.’[10]
1.34The banking sector continues this argument with the Customer Owned Banking Association (COBA) saying it is unclear ‘exactly how the SPF Principles contained in the SPF Bill and the future Codes will interact. We are particularly concerned about situations where our members acting in good faith have met all their requirements under the Code could still be found to have breached the Principles and be subject to significant penalties.’[11]
1.35The Australian Banking Association (ABA) calls on the government to ‘Streamline the interaction of the SPF Principles and Industry Codes to provide clear investment incentives’[12]by amending the legislation ‘such that, in a sector where a Code has been approved and issued, compliance with that Code is taken to be compliance with the SPF Principles.’[13]
1.36Whether the Committee accepts the entreaties of regulated entities and their representatives to move specific obligations from the framework to the code, or those of regulators and consumer advocates to enshrine more specific obligations in the framework, there is clearly a need for more clarification on the interaction between obligations created under the framework and under industry codes and as against existing consumer and other legislation.
Recommendation 1
1.37Revisit drafting in the bill to provide greater clarity on how obligations under the framework and the industry codes will interact and co-exist, also providing greater certainty to regulated entities about the nature of their obligations.
1.38The Member for Warringah, Zali Steggall OAM MP, has put forward an amendment, which the government has indicated it will support, that would require regulated entities, ‘When undertaking such internal dispute resolution about a complaint, the entity must give a statement, relevant to the complaint, about whether it has complied with its obligations.’ This amendment addresses concerns also raised by the ACCC in their submission. I also support this amendment. The Consumer Organisations have called for this amendment to go further, explicitly place the burden of proof on the regulated entity to prove it met its obligations and giving AFCA the power to verify such statements.
Recommendation 2
1.39Strengthen and support the amendment moved by the Member for Warringah.
1.40The Committee has been presented with conflicting evidence and models about how liability in the case of scam losses should be apportioned by actors in the scam chain.
1.41Telcos argue that they are limited by existing regulations in the extent to which they can monitor and disrupt scams as carriers.
1.42The Australian Banking Association and its members argue that scams ‘do not originate with banks’ and ‘digital platforms must fully participate in a co-ordinated national anti-scam defence’.[14]
1.43Digital platforms, meanwhile, argue the reverse, that banks bear the greatest liability as they control the money.
1.44DIGI argues that it is ‘important to emphasise that digital platforms, including social media services, are not an equal vector as the banking and telecommunications sector in relation to scams. According to Australians’ reports to Scamwatch in 2023, text message remains the most popular method of choice for scammers (34 per cent), followed by phone call (27 per cent). 5.8 percent of contacts came from ‘online forums’, which includes a much wider range of websites including professional trading websites, of which social media is a quantifiably unknown subset.’[15]
Source: National Anti-Scams Centre, National Anti-Scam Centre in Action: Quarterly Update, p. 6.
1.45While it is clear that all parties in a scam chain must play their part in combatting and preventing scams and scam losses, the onus needs to remain on ensuring that scam victims are promptly compensated.
1.46A number of submissions point to Singapore’s Shared Responsibility Framework as one model for apportioning liability among regulated entities.
1.47The Communication Alliance recommends a ‘waterfall approach’ to compensation: banks, as custodians of consumers’ monies, pay full compensation if found in breach of their sector-specific obligations. If banks are in compliance with their respective obligations but other sector(s) are not, those other sector(s) pay compensation, through a scheme of apportioning compensation yet to be determined through further consultation.[16]
1.48The Consumer Organisations have jointly called for the bill to ‘provide a high-level principle for apportioning liability between regulated entities, including amending Subdivision G Part IVF of the SPF Bill to provide that following a breach of the Framework, at least one regulated entity will be required compensate the consumer for the related scam losses in their entirety, with contributions from other regulated entities to be handled directly between culpable entities or via a compensation pool.’[17]
1.49‘The ACCC supports AFCA’s position in its submission to Treasury’s consultation on the then-named Scams Code Framework that there should be ‘a clear articulation of liability for losses arising from scam complaints and, if there are to be multiple parties (within and across sectors) that might share liability in a particular case, clarity about how liability will be allocated’.
1.50‘Determining and apportioning liability on a case-by-case basis will be complex and resource-intensive, and risks causing additional distress to victims throughout the process.’[18]
1.51The Telecommunications Industry Ombudsman recommends ‘that the SPF Bill be amended to include guiding principles to assist with addressing the question of multi-party liability for scam losses .’[19]
Recommendation 3
1.52Amend the bill to provide guidance on how liability for scam losses should be apportioned in cases of non-compliance with the framework and code, and a mechanism for resolving this between regulated entities, with intervention from regulators as required.
1.53From a consumer perspective, the biggest shortfalling of the bill is in its treatment of compensation for scam victims.
1.54This is highlighted not only by the Consumer Organisations in their joint submission, but also by regulators and some of the SPF regulated entities.
1.55For example, ‘The ACCC encourages consideration of different models for consumer redress and compensation in IDR and EDR processes, such as appropriately designed and regulated compensation pools.’[20]
1.56DIGI warns that ‘Under the proposed Australian scheme, there could be a protracted examination through an external dispute resolution body of different companies’ relative roles in the scammers’ attack, in order to determine possible redress. Unlike the UK scheme, redress under the Framework could take years for people who have lost their life savings because of the sheer number of different services scammers exploit in their complex attack chain.[21]
1.57Optus recommends ensuring ‘that Division 6 delivers simple, fast and effective redress for consumer harm. Division 6 should clarify that IDF, EDF, and regulator actions focus on compensating consumers for any loss incurred as a result of non-compliance with SPF codes under Division 3.’[22]
1.58Mr David Niven, a consumer lawyer with 44 years’ experience helping consumers and one of the two drafters of the first electronic consumer protection laws, the Victorian ePayments Code in the 1980s who has more recently been running cases at Australian Financial Complaints Authority (AFCA) for HSBC scam victims and providing advice to the HSBC action group warns says he ‘strongly support[s] a Scam Bill along the lines of the UK Reimbursement model.’[23]
1.59However Mr Niven ‘strongly oppose[s] the Government’s proposed Scam Bill. Not just because it fails to follow the UK model, but far more importantly, because it does not provide meaningful protection for consumers and it is likely to significantly reduce consumers’ ability to obtain refunds compared to the current position.’[24]
1.60This would appear to be supported by the ABA’s submission which calls for ‘The legislation be amended to remove the right to bring individual causes of action against REs’.[25]
1.61Mr Niven says the burden on consumers to prove their case will be even harder, consumers may have to go to the Federal Court to get their refund and consumers' current rights may well be lost.
1.62Mr Niven warns rather alarmingly that ‘The legislation is, in effect, likely to protect banks, especially smaller banks from being liable to refund scam losses.’ He says there is ‘the very real prospect that HSBC victims would have been worse off under the Bill.’[26]
1.63He recommends inserting the following provision:
‘Nothing in this Act or the SPF Codes:
(a) in any way limits or derogates from any rights that a person who suffers loss or damage as a result of a scam has under other laws or codes of conduct, or
(b) sets a lower standard of conduct required of a regulated entity under any other law or code of conduct.’[27]
1.64The Consumer Organisations have jointly called for government to ‘Insert an amendment to clarify that if a regulated entity does not meet its obligations under the Scams Prevention Framework Bill 2024, Rules or Codes, there is a presumption that the regulated entity will compensate the SPF consumer.’[28] While not replicating the UK model, this proposal provides a default response to breaching either the framework of sector/code that would enable compensation to flow quickly to the consumer.
Recommendation 4
1.65Amend the bill to insert the provision recommended by Mr Niven outlined above.
Recommendation 5
1.66Amend the bill to ensure that, in circumstances where via either an EDR or IDR process, a regulated entity is found not to have complied with its obligations under the SPF framework and industry code, a presumption is made to compensate the victim. If multiple entities are in breach, compensation will be paid by the entity deemed most at fault to enable faster, more seamless payment to the scam victim. This presumption should apply except in limited circumstances such as gross negligence of the victim. The bill will establish a mechanism and formula to subsequently apportion liability among those regulated entities found to have been in breach of their obligations.
1.67In its submission the ACCC raises the issue of sharing of personal information. This is something also raised privately with my office by a number of regulated entities.
1.68Specifically, the ACCC as the general regulator for the new framework says:
‘The Scams Prevention Framework does not currently authorise the ACCC, as the Scams Prevention Framework general regulator, to share personal information with private sector entities that are not ‘regulated entities’ to disrupt scams (see section 58BV of the Bill)...The ACCC considers it essential that the Scams Prevention Framework authorise fast and efficient sharing of personal information.’[29]
Recommendation 6
1.69Amend the bill to enable the sharing of personal information in appropriate circumstances and with adequate privacy protections.
1.70The three biggest issues scam victims have raised with me are lack of compensation, information asymmetry between scam victim and entity, and scam warnings.
1.71Too many cases have come to light where an entity has either received warnings from a regulator like ASIC or experienced their own systems failure that enables large scale scams to continue to be perpetrated for far too long.
1.72In too many of these cases it has been too hard for victims to seek the reimbursement they deserve. Too often this task is complicated by a failure to be able to access information held by the entity, but the scam victims need to prove their case.
1.73These are all elements the bill does not adequately address.
1.74It is something highlighted in the ACCC, ‘As identified in our October 2024 submission, the ACCC should be able to require regulated entities (or authorised third-parties) to meet certain requirements for data sharing. This includes the recommendation that the time-period prescribed for reports under the Scams Prevention Framework could be covered by Notifiable Instruments, rather than in the Scams Prevention Framework rules.’[30]
1.75From the regulated entities’ perspective, they also raise concerns that the reporting provisions in the bill are so broad as to become ineffective at stopping actual scams being perpetrated.
1.76Digi has expressed concern about the reporting requirements as currently drafted suggesting ‘The ACCC is likely to be inundated with millions of low-quality reports about potential scams that might not even eventuate to a serious concern in Australia…Reporting requests should be scoped towards clear outcomes, including what meaningful actions will be taken with the information shared.’[31]
1.77‘DIGI requests that the Committee recommends that any actionable reports shared with the NASC, through the Framework or the NASC’s existing operations, be used to develop a public, searchable database of known scams that consumers and companies can use to investigate whether something is a scam in real-time.’[32]
1.78‘DIGI urges the Government to provide the ACCC with the power to issue takedown requests with respect to specifically identified content and accounts associated with known scam relevant services, expanding the current ASIC investment scam takedown scheme to other scam types (e.g. impersonation scams).’[33]
1.79‘If obligations to act on scam reports are retained, they must be limited to scams that meet internal thresholds of suspicion, as opposed to all scam reports made by consumers.’[34]
1.80Google also raises concerns about threshold issues around takedown provisions and scam reporting.
1.81The ABA calls on government to ‘Ensure that ‘actionable scams intelligence’ is actionable and ensure that expectations on organisations are clear’[35] by providing ‘the Minister with the power to issue SPF Rules that more clearly define actionable scam intelligence.’[36]
Recommendation 7
1.82More clearly define actionable scam intelligence in the bill and empower the ACCC to request specific data sharing from regulated entities.
1.83In addition to the concerns outlined above about the interaction of the overarching framework and the industry codes, specific concerns have been raised about the operation of definitions.
1.84The Mortgage and Finance Association of Australia expresses its support for the Australian Banking Association’s proposal ‘to include a non-exhaustive list in the Rules of what is not considered to be scam activity including fraud where parties are known to each other, ponzi schemes and misleading and deceptive conduct. Such a list will support greater clarity to entities within designated sectors to comply with the SPF.’[37]
1.85Similar concerns are raised by digital companies, with DIGI saying ‘The standard in section 58BO ‘fails to take reasonable steps within a reasonable time’ is inherently subjective, and is likely to lead to disagreements between individuals and companies around what they consider that they are undertaking reasonable steps. This underscores the importance of cross-referencing the sectoral codes as the clear description of what ‘reasonable steps’ entails. While we acknowledge that section 58BP indicates that sector-specific details can be set out in SPF codes, entities can still be breach of overarching principles while meeting the obligations set out in sectoral codes.’[38]
Recommendation 8
1.86Better define scam as well as reasonable steps and reasonable timeframes in the primary legislation and articulate how definitions in the framework will interact with those in the codes.
1.87A key feature of the proposed framework is a ‘no wrong door’ approach for consumers who have fallen victim to a scam. It provides for both internal and external dispute resolution processes. However, all stakeholder cohorts express concern at the complexity of the dispute resolution processes outlined.
1.88The Telecommunications Industry Ombudsman is uniquely placed to advise the committee on dispute resolution as it is currently the external dispute resolution body for the telecommunications industry. Concerningly, it describes the bill’s approach to both internal and external dispute resolution as ‘unworkable’.[39]
1.89The Telecommunications Industry Ombudsman recommends:
… amending subdivision G of the SPF Bill to ensure that subordinate instruments provide for minimum IDR standards on specific matters, including:
minimum response times for regulated entities that receive IDR complaints for consumers (this is echoed in the Consumer Organisations joint submission).
information regulated entities must provide to consumers
the contact methods and process for consumers to bring a complaint to one or more regulated entities
the point at which a consumer can access EDR where IDR has failed.[40]
1.90Google echoes warnings contained in other submissions saying ‘The proposed internal dispute resolution (IDR) and external dispute resolution (EDR) processes are extremely complex and could lead to perverse outcomes — including making Australia more appealing to scammers rather than less. Consumer groups have confirmed the current proposal would be ‘unworkable’ for consumers.’[41]Overlapping obligations between the framework and industry codes is also raised as a concern by Google in their submission.
1.91Multiple submissions to the senate committee also note that the proposed framework may lead to a significant increase in the number of complaints lodged with AFCA, and express concerns that AFCA may not have sufficient resources to handle the increased volume of claims.
1.92This is in the context of an organisation already overwhelmed by its current workload with reports of ‘banking, insurance and super customers are suffering delays of up to six months to have managers assigned to complaints.’[42]
1.93AFCA’s own website acknowledges it ‘is currently experiencing delays in allocating complaints to its Dispute Resolution Specialists due to a significant increase in complaints across most product areas – particularly in insurance due to floods, and banking due to scams.[43]
Recommendation 9
1.94The government should revisit the dispute resolution mechanisms envisaged in the legislation to simplify the process for consumers and clarify obligations for regulated entities. The Government also needs to further increase resources to AFCA (over and above the grant already provided) and other regulators to ensure they are adequately resourced to deal with the new functions provided for in this legislation.
1.95The Minister has indicated that he initially intends to initially designate three sectors under the framework:
Banking sector
Telecommunications sector
Digital platform services (initially social media, paid search engine advertising, and direct messaging services)
1.96Additionally, the dataset mentions that the Government has signalled its intention to bring in other sectors under the Framework in the future, including:
Superannuation funds
Digital currency exchanges
Other payment providers
Transaction-based digital platforms (such as online marketplaces)
1.97In its submission to the committee, Super Consumers Australia underscores the importance of including Australia’s $4.1m superannuation industry as a designated sector ‘no later than eight months after the SPF receives Royal Assent’ warning that ‘Consumers are likely to suffer significant detriment if the superannuation sector is subject to a longer delay in being added to the framework.’
Recommendation 10
1.98The Government should move to designate the superannuation industry as soon as practicable.
Senator David Pocock
Participating Member
Independent Senator for the Australian Capital Territory
Footnotes
[1]Australian Competition & Consumer Commission, ‘Scam losses decline, but more work to do as Australians lose $2.7 billion’, Media release, 28 April 2024.
[2]Australian Competition & Consumer Commission, ‘Anti-scam practices of banks outside the four major banks’, Media release, 20 August 2024.
[3]Australian Competition & Consumer Commission, Submission 3, p. 2.
[4]Optus, Submission 15, p. 2.
[5]Telecommunications Industry Ombudsman, Submission 7, p. 3.
[6]Australian Competition & Consumer Commission, Submission 3, p. 3.
[7]Telecommunications Industry Ombudsman, Submission 7, p. 3.
[8]Digital Industry Group Inc., Submission 6, p. 3.
[9]Optus, Submission 15, p. 2.
[10]Insurance Council of Australia, Submission 12, p. 4.
[11]Customer Owned Banking Association, Submission 19, p. 3.
[12]Australian Banking Association, Submission 33, p. 8.
[13]Australian Banking Association, Submission 33, p. 9.
[14]Australian Banking Association, Submission 33, p. 2.
[15]Digital Industry Group Inc., Submission 6, p. 4.
[16]Communications Alliance, Submission 11, p. 3.
[17]Joint Consumer Organisations, Submission 31, p. 3.
[18]Australian Competition & Consumer Commission, Submission 3, p. 2.
[19]Telecommunications Industry Ombudsman, Submission 7, p. 4.
[20]Australian Competition & Consumer Commission, Submission 3, p. 3.
[21]Digital Industry Group Inc., Submission 6, p. 5.
[22]Optus, Submission 15, p. 3.
[23]Mr Davis Niven, Submission 38, p. 1.
[24]Mr Davis Niven, Submission 38, p. 1.
[25]Australian Banking Association, Submission 33, p. 9.
[26]Mr Davis Niven, Submission 38, p. 2.
[27]Mr Davis Niven, Submission 38, p. 4.
[28]Joint Consumer Organisations, Submission 31, p. 3.
[29]Australian Competition & Consumer Commission, Submission 3, p. 4.
[30]Australian Competition & Consumer Commission, Submission 3, p. 5.
[31]Digital Industry Group Inc., Submission 6, p. 3.
[32]Digital Industry Group Inc., Submission 6, p. 8.
[33]Digital Industry Group Inc., Submission 6, p. 9.
[34]Digital Industry Group Inc., Submission 6, p. 19.
[35]Australian Banking Association, Submission 33, p. 8.
[36]Australian Banking Association, Submission 33, p. 10.
[37]Mortgage and Finance Association of Australia, Submission 4, p.2
[38]Digital Industry Group Inc., Submission 6, p. 25.
[39]Telecommunications Industry Ombudsman, Submission 7, p. 5.
[40]Telecommunications Industry Ombudsman, Submission 7, p. 5.
[41]Google, Submission 18, p.2.
[42]https://www.theaustralian.com.au/business/afca-complaints-backlog-leading-to-lengthy-waits-for-case-assessment/news-story/496689135e5fd00dc58112c95fd779bb
[43]Australian Financial Complaints Authority, Delays in allocating Dispute Resolution Specialists, www.afca.org.au/what-to-expect/the-process-we-follow/delays (accessed 3 February 2025).
An inquiry into the provisions of the Scams Prevention Framework Bill 2024.
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