CREDIT REPAIR AUSTRALIA Pty Ltd ( CRA ) A.C.N CODE OF CONDUCT IN RELATION TO CREDIT RESTORATION SERVICES

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1 CREDIT REPAIR AUSTRALIA Pty Ltd ( CRA ) A.C.N CODE OF CONDUCT IN RELATION TO CREDIT RESTORATION SERVICES 1. SHORT TITLE 1. Short title. 2. Background & Purposes. 3. Definitions. 4. Prohibited Practices. 5. Requirements of Associates 6. Training and Development. 7. Disclosures. 8. Consumer Needs Analysis 9. CRA Agreements. 10. Right to cancel an Agreement. 11. Non-compliance with this Code of Conduct 12. Disciplinary Action 13. Amendments 14. Effective date. This title may be cited as the 'Credit Restoration services Code of Conduct '. 2. BACKGROUND & PURPOSES 2.1 Background (a) Consumers have a vital interest in establishing and maintaining their credit worthiness and credit standing in order to obtain and use credit. As a result, consumers who have experienced credit problems may seek assistance from CRA (b) This could lead to consumers with limited economic means and who are inexperienced in credit matters or consumers who may be insolvent attempting to improve their credit worthiness/ rating. (c) CRA believes that there are mainly two types of consumers being: i. Consumers with a past credit problem. These consumers are currently solvent although may not be able to obtain credit or are paying higher interest rate due to past problems which are listed on the consumer s credit report. ii. Consumers with a current credit problem. These consumers are insolvent and are not able to pay their bills as and when they fall due. The first priority of these customers should be to resolve their current debts and any service provided should not create further financial hardship for these consumers. 2.2 Purposes.--The purposes of this title are-- (a) to ensure that prospective buyers of CRA s Credit Restoration service are provided with the information necessary to make an informed decision regarding the purchase of such services; and (b) to protect the public, particularly those with limited financial means and who are inexperienced in credit matters; and

2 (c) to ensure that systems and procedures are maintained by CRA in identifying solvent and insolvent consumers and therefore only providing options which are not unsuitable to prospective consumers. 3. DEFINITIONS. For purposes of this title, the following definitions apply: 3.1 Associate. The term Associate means any employee, officer, manager, director, agent or representative of CRA 3.2 Consumer. -- The term 'consumer' as defined by the National Credit Act. 3.3 Consumer credit transaction. -- The term 'consumer credit transaction' means any transaction in which credit is offered or extended to an individual for personal, family, or household purposes. 3.4 Credit.--The term 'credit' has the meaning given to such term in included in the National Credit Act 3.5 Credit Restoration -- The term 'Credit Restoration'-- means any person, business or corporation who sells, provides or performs (or represents that such person, business or corporation can or will sell, provide, or perform) any service in return for the payment of money or any other valuable consideration for the purpose of: (a) improving any consumer's credit record, credit history, credit file or credit rating; or (b) providing advice or assistance to any consumer with regard to any activity or service described in clause (i) 3.6 Engagement means an agreement between CRA and the Consumer. 3.7 Financial Hardship a consumer suffers an unexpected material change in their life which results in them being unable to meet their financial obligations. This may be as a result of illness, injury, accident or other unforeseen occurrence. 3.8 Material Convictions The term Material Convictions means an offence under the Criminal Code Act National Credit Act The term National Credit Act means National Consumer Credit Protection Act (cth) 2009.

3 4. PROHIBITED PRACTICES 4.1 In General. No Associate or Person shall; (a) make any statement, or counsel or advise any consumer to make any statement, which is untrue or misleading (or which, upon the exercise of reasonable care, should be known by CRA, officer, employee, agent, or other person to be untrue or misleading) with respect to any consumer's credit worthiness, credit standing, or credit capacity to-- i. any consumer reporting agency (as defined in the Privacy Act) ii. any person-- (i) who has extended credit to the consumer; or (ii) to whom the consumer has applied or is applying for an extension of credit; (b) make any statement, or counsel or advise any consumer to make any statement, the intended effect of which is to alter the consumer's identification to prevent the display of the consumer's credit record, history, or rating for the purpose of concealing adverse information that is accurate and not obsolete to-- i. any consumer reporting agency; ii. any person-- (i) who has extended credit to the consumer; or (ii) to whom the consumer has applied or is applying for an extension of credit; (c) make or use any untrue or misleading representation of the services of the Credit Restoration; or (d) engage, directly or indirectly, in any act, practice, or course of business that constitutes or results in the commission of, or an attempt to commit, fraud or deception on any person in connection with the offer or sale of the services of Credit Restoration. (e) not engage any Consumer for the purpose of providing Credit Restoration services, where CRA reasonably believes that the Consumer is suffering (or is likely to suffer) Financial Hardship as a result of providing the service. 4.2 Payment in Advance.- Unless a Consumer Needs Analysis of prospective consumer financial position has been completed then: (1) CRA will not charge or receive any money or other valuable consideration for the performance of any Credit Restoration service that has agreed to perform for any consumer before such service is performed. 4.3 Guarantees and overstatement of success No Associate of CRA can issue any guarantee to consumers requiring Credit Restoration services relating to any outcome of a matter that is listed on a credit report; or (a) make any guarantees relating to time-frames or (b) overstate the likelihood of success

4 5. REQUIREMENTS OF ASSOCIATES 5.1 All Associates engaged in Credit Restoration services must hold a Police Clearance Report that has no material convictions. 5.2 A copy of the Associates Police Clearance Report must be held on the employees HR file. 5.3 Any person involved with Credit Restoration must have completed and passed a relevant training course and hold a certificate of attainment. CRA Training Course and hold a certificate of attainment as a Credit Repair Associate. 5.4 Conflict of Interest.- Associates must: (a) disclose any conflict of interest as soon as is reasonably practicable and disclose the existence of any agency arrangements or other commercial relationships as would be reasonably determined under common law. (b) disclose in writing prior to the Client accepting any Credit Restoration service the source of any fees, other remuneration or benefit to be received by the CRA and in such detail as may be required by law in the lawful jurisdiction of both CRA and the Consumer. (c) disclose in writing prior to the Consumer being legally bound to any Credit Restoration service, of the payment of any type of fee, remuneration or other benefit, in the event that the payment of the fee, trailing commission, other remuneration or benefit to any referrer, subcontractor or third party where such third party shall from time to time, give advice relating to the proposed transaction or otherwise assist or induce the Client to enter into the transaction and it shall be in such detail as may be required by law in the lawful jurisdiction of both CRA and the Consumer. 5.5 Confidentiality and Privacy- At all times CRA and it s Associates will maintain the confidentiality of Client details and other information in accordance with the Privacy Act 1988 and any subsequent amendments. 5.6 Ethics and Fairness -CRA and its Associates will act ethically and fairly in the provision of Credit Restoration services. 6. TRAINNING AND DEVELOPMENT CRA and its employees shall endeavour to continually ensure that systems and procedures are maintained and relevant training is undertaken by staff. 7. DISCLOSURES 7.1 Disclosure Required.-- CRA shall provide any Consumer with the following written statement before any contract or agreement between the Consumer and CRA is executed: 'Your Credit File You may dispute inaccurate and contestable information in your credit report by contacting the Credit Reporting Agency, Credit Provider, Ombudsman or The Office of the Australian Information Commissioner directly. However, neither you nor any' Credit Restoration organisation can have accurate, current, and verifiable information removed from your credit report. Credit Reporting Agencies will remove accurate information on your report if it is over 5 years for Defaults, Clear-Outs 7 years, Serious Credit Infringement 7 years, Judgements 5 years, Court Writs 4 years, Credit Enquiries 5 years, Previous Directorships 10 years. Bankruptcy information can be reported for 7 years.

5 Credit Providers are required to follow reasonable procedures to ensure that the information they report is accurate. However, mistakes may occur. You may, on your own, notify a Credit Reporting Agency, the relevant Ombudsman or The Office of the Australian Information Commissioner that you dispute the accuracy of information in your credit file. If you are in financial hardship, you may also be able to seek free assistance from a financial counsellor. The Credit Reporting Agency may then investigate and modify or remove inaccurate or incomplete information. The Credit Reporting Agency, Ombudsman or The Office of the Australian Information Commissioner is unlikely to charge any fee for this service. Any pertinent information and copies of all documents you have concerning an error should be given to these entities. If the Credit Reporting Agency s investigation does not resolve the dispute to your satisfaction, you may send a brief statement to the credit reporting agency, to be kept in your file, explaining why you think the record is inaccurate. The Credit Reporting Agency may include a summary of your statement about disputed information with any report it issues about you. The Office of the Australian Information Commissioner regulates Credit Reporting Agencies. For more information, contact: The Office of the Australian Information Commissioner GPO BOX 5218 Sydney NSW 2001 Or phone You have the right to cancel your agreement with CRA for any reason within 3 business days from the date you entered into the agreement. If you have a complaint relating to our service you can lodge it through our Internal Dispute Resolution (IDR) process by contacting us in writing at: Internal Disputes Resolution CRA P.O. Box 392 Moorebank NSW 1875, OR phone Please allow us 45 days to resolve your complaint, however most cases are resolved much sooner. If we have not resolved your dispute after 45 days, you may decide to escalate the matter to be addressed by an independent third party. This can be done by lodging the complaint with the External Disputes Resolution (EDR) body of which we are a member: Credit Ombudsman Service Limited (COSL) PO Box A252 Sth Sydney NSW 1235 OR phone Separate Statement Requirement.--The written statement required under this section shall be provided as a document which is separate from any written contract or other agreement between the CRA and the consumer or any other written material provided to the consumer. 7.3 Retention of Compliance Records. (a) In general. CRA shall maintain a copy of the statement that has been forwarded to the consumer. (b) Maintenance for 7 years.--the copy of any statement shall be maintained in the organisation's file for 7 years after the date on which the statement is confirmed /acknowledgement by the consumer by recording, signing or electronic transmission.

6 8. CONSUMER NEEDS ANALYSIS 8.1 Consumer Needs Analysis is Compulsory- Prior to any Associate providing any Credit Restoration services to an entity a Consumer Needs Analysis, based on information provided by the consumer, needs to be completed. 8.2 The Consumer Needs Analysis needs to cover the following points: (a) What the consumer is attempting to achieve, and (b) Liabilities of the consumer, and (c) Debt status of the consumer, and (d) Assets of the consumer, and (e) Income of the consumer, and (f) Budget and serviceability of the consumer, and (g) Information on: i. the solvency status of an entity, and ii. the consumer about the affordability regarding payments for services, and iii. the possibility of any unconscionable conduct that could occur/ has occurred. 8.3 Currency of Consumer Needs Analysis-- The Consumer Needs Analysis must be within 90 days prior to consumer entering into a contract with CRA. 8.4 Filing--The Consumer Needs Analysis must be on the Consumers file for a period of 7 years. 9. CRA CONTRACTS AGREEMENTS 9.1 Agreements Required.--No services may be provided by CRA for any consumer (a) unless a Consumer has entered into a lawful contract that meets all legislation prior to the provision of Credit Restoration services; and (b) a copy of the contract has been sent to the Consumer within a reasonable period of time. 9.2 Terms and Conditions of Contract.--No contract referred to in this subsection meets the requirements of this subsection unless it included: (a) the terms and conditions of payment, including the total amount of all payments to be made by the consumer to the Credit Restoration service or to any other person; (b) a full and detailed description of the services to be performed by CRA for the consumer, including-- i. all warranties of performance; and ii. an estimate of-- (i) the time by which the services could be completed; or (ii) the length of the period necessary to perform such services;

7 (c) CRA name and principal business address; 9.3 Service fees- In the event that the service being provided by CRA is a Credit Restoration service and no matters listed in the appointment terms are successfully negotiated, within a 12 month period from receiving a signed privacy consent form and the information provided by the consumer is true and correct, then the service fee will be refunded to the consumer upon request. 10. RIGHT TO CANCEL AN AGREEMENT 10.1 In General. -- Any consumer may cancel any agreement with CRA without penalty or obligation by notifying CRA of the Consumer's intention to do so at any time before 5pm Eastern Standard Time of the third business day which begins the date on which the contract or agreement between the consumer and CRA is executed or would be executed Cancellation and Other Information. -- Each agreement or contract shall contain a statement which has the heading 'Notice of Cancellation' and contains: (a) A clear statement as follows: You may cancel this agreement without penalty or obligation at any time before 5pm Eastern Standard Time on the third business day after the date of engagement NON COMPLIANCE WITH THIS CODE OF CONDUCT Agreement Not in Compliance after the 1 st February Any new contracts or new agreements created for services after the 1 st February 2014 which does not comply with the applicable provisions of this Code-- (a) shall be treated as void; and (b) Any person or associate that does not comply with this Code of Conduct will deem to be in breach of CRA s Company Policy. 12. DISCIPLINARY ACTION. Any Associate--who fails to comply with any provision of this code with respect to any other person shall be liable to disciplinary action as determined by the Board of CRA. 13. AMENDMENTS This Code shall be amended in writing from time to time as necessary and do so in writing by the Board of Directors of CRA Pty Ltd 14. EFFECTIVE DATE This Code of Conduct has been Board approved on the 5 th of December 2013 and will be effective on any contracts or Agreements commencing

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