Legislative Review and Mutual Evaluation Criminal Law and Law Enforcement Branch Attorney-General's Department 4 National Circuit BARTON ACT 2600

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1 Submission to Legislative Review and Mutual Evaluation Criminal Law and Law Enforcement Branch Attorney-General's Department 4 National Circuit BARTON ACT 2600 Re: Issues Paper AML/CTF Act Review Submitted via to Contact: Philip Johns CEO National Financial Services Federation Ltd P: F: M: E: Postal Address: Suite 156, 192 Ann St, Brisbane Qld 4000

2 The National Financial Services Federation (the Federation) welcomes the opportunity of providing a submission in response to the issues paper released by AUSTRAC and the Attorney-General s Department in December It is noted that the paper was issued as part of the statutory review of the operation of the Anti-Money Laundering and Counter-Terrorism Financing Act So that some context can be given to the submission by the Federation, we intend to provide some background information on the Federation, its members and the operation of its members within the provisions of the Anti-Money Laundering and Counter-Terrorism Financing Act BACKGROUND TO THE FEDERATION The National Financial Services Federation is the peak national industry association representing over 180 ASIC-licensed short-term credit providers serving over 650,000 consumers each year. The Federation has a diverse membership that covers Franchisors, Franchisees, private and publicly listed companies who offer consumer credit (as opposed to business credit) products ranging from small amount credit contracts (often referred to as payday loans) to personal longer term loans from both retail outlets and dedicated online platforms. The Federation has been heavily involved in Government consultation processes since July 2008 when the Commonwealth began taking over regulation of consumer credit from the States. The last five years has seen the Federation develop into an effective entity for representing the industry sector, submission responses and one-on-one consultation with key government authorities such as the Commonwealth Treasury and ASIC and continues to welcome and appreciate ongoing consultation. Information about Federation members Federation members are holders of Australian Credit Licences issued by ASIC pursuant to the National Consumer Credit Protection Act 2009 ("National Credit Act"). The vast majority of them are credit providers Page 1 of 7

3 lending their own money to consumer applicants for small loans. Individual members range from operators having one office staffed by as few as one or two persons to larger entities which may have multiple outlets or which may offer borrowing facilities online. Amounts lent for these consumer loans range from $50 to $5,000, for terms generally from a number of weeks up to 2 years. Some members provide just the one type of loan and some provide a range of loan services and other financial products. All of the Federation s members rely on the banking system to trade. Disbursements of credit to borrowers by the Federation s members is made in the majority by direct deposits into the borrowers bank accounts or cash over the counter. In excess of 98% of all repayments made by borrowers to the Federation s members are made by the use of direct debit facilities operated either by the Federation s member s own arrangements with a bank, or through the engagement of a third party DDR supplier. All electronic transactions of the Federation s members are made through an Approved Deposit Taking Institution (ADI). Restrictions of Australian credit licences Licensees operating under the provisions of the National Credit Act have two sets of "rules" which apply to them pursuant to that Act. These are either conditions which apply to the Australian Credit License specifically, or general conditions which apply by virtue of the provisions of the Act itself. There are significant obligations on ASIC licensed credit providers in this sector, particularly in terms of the circumstances under which a loan can be advanced. It is a statutory requirement before a loan can be advanced by the credit provider to obtain a significant amount of financial and other information from the applicant and for that information to be verified. Federation members generally offer loans in circumstances where borrowers cannot access mainstream lending through the banks or other Page 2 of 7

4 ADIs, or choose not to, as a result the risk of the loan not being repaid are higher than would be expected in the general population. The result of these Australian Credit License obligations and some consumer s circumstances is that a higher degree of pre-loan enquiry is made both to ensure that the statutory requirements are complied with and to ensure that the risk to the credit provider is minimised. It is inherently in the interest of the credit provider to minimise exposure by the consumer to potential financial hardship and ensure the consumer has the capability to meet their obligations. Federation members, in the main, lend their own money so it is in their best business interest to lend only to those individuals who will be able to repay. Federation members as AUSTRAC reporting entities During the period leading up to December 2007 when it became a requirement for businesses which were "reporting entities" under the provisions of the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 to have an AML/CTF program, AUSTRAC undertook the process of providing training for those businesses. AUSTRAC recognised that there were various divisions within the reporting entity sector which had different requirements due to their different business models, clients and, to a large degree, risk profiles. A specific task force was set up by AUSTRAC to deal with the sector. That sector now turns out to be that from which the majority of Federation members come. Member customers are individuals not corporations Information AUSTRAC will have collected since 2007 (particularly that which will be contained in the various AML/CTF programs obtained or reviewed by AUSTRAC since 2007) will show that those ASIC licensed credit providers who are Federation members have a very particular customer type base. Almost without exception, the persons with whom Federation members deal are individuals who borrow amounts under what are now known as Page 3 of 7

5 "small amount credit contracts" or "medium amount credit" contracts (as those terms are defined in the National Credit Act). In other words, they are consumer loans (as opposed to business loans) of up to $5,000 for periods of time generally from 16 days to 2 years. Very few Federation members lend outside these parameters and for those who do, the vast majority of advanced loans fall within those parameters. To reiterate, Federation members lend small amounts of money for short periods of time to borrowers who are individuals (as opposed to a company, trust, partnership, association, registered cooperative, or government body). Notwithstanding the provisions of the National Credit Act, so far as a credit provider is concerned and from a practical point of view, the identity of the borrower is the most important item to establish. Once payment has been made to a borrower, all the risk is then on the credit provider and if proper enquiries have not been made as to identity, chances of recovering the funds, which in general are the credit provider s own funds, are greatly reduced. The Federation s members do not lend to people whose identity has not been absolutely established. ML/TF risk All of the Federation s members have a written AML/CTF program. It is a requirement of that program for an assessment to be made of the ML/TF risk associated with the reporting entity s activities. The assessment made by Federation members is that the ML/TF risk is low. This is based upon the business model undertaken by the Federation s members including:- a. The size of the transactions involved. The range of loans for a Small Amount Credit Contract is up to $2000, whilst for Medium Amount Credit Contracts the range is $2001 TO $5000. Whilst the Federation concedes that a number of these loans could, as a group, be used for ML or TF, individually they would be a less than ideal method of achieving that aim. b. The type of services provided. The core service provided is that of a regulated loan under the National Consumer Credit Protection Act 2009, most often paid into the borrower s ADI account. Page 4 of 7

6 c. The fact that no loan is advanced without a written application having been made. This application could be made in hard copy or by submission electronically. In every case a rigorous check is made of identity, income and other financial information, all of which is verified independently of the applicant. Independent referees are also sought. d. The method used to deliver the services. Loans are advanced after a written application is made with significant personal and other details being recorded and verified. Identity is always independently confirmed. e. The enquiries undertaken before a loan is advanced. These include direct enquiries of the applicant where appropriate, together with queries of public databases (telephone listings for example) and where appropriate other sources such as credit reporting agencies, contact with employers, relatives, friends and landlords). f. The demographic of persons applying for loans. In particular it is a fact that no politically exposed person has, to the best of the information available to the Federation, applied for a loan through one of its members. g. No foreign jurisdiction is involved in the vast majority of loans. All services are conducted within Australia with Australian ADIs and in most cases Australian ADIs provide the method of the receipt and transfer of funds. In addition, as referenced in f. & g. above, the use of small value loans does not appear as a recognised method of ML/TF in any of the Typologies and Case Studies Reports issued by AUSTRAC since There are mentions of fraud being undertaken using "loans", but not specifically small amount loans. Case 22 in the 2010 report, for example, refers to money obtained from a Fijian fraud being used to pay Australian credit card debt, but the amount involved was in the order of $240,000. To affect that sort of payment even at the higher end of the loan amounts conducted by the Federation s members would require several dozen loan applications. Page 5 of 7

7 ISSUES PAPER The Federation wholly supports the AML/CTF regime and its existence. It is the recommendation of the Federation that consideration should be given to exempting sections of the small amount money-lending market from parts of the operation of the AML/CTF regime. In making the submission, the Federation acknowledges the current objectives of the AML/CTF regime set out in the issues paper:- To detect and deter ML/TF and reduce the risk to the integrity of the financial system; To provide officials with information necessary to investigate and prosecute ML/TF, thereby reducing crime; To apply a risk-based approach that strikes an appropriate balance between AML/CTF measures and the efficient conduct of business; To provide Australia s financial intelligence unit and AML/CTF regulator with powers to collect information, supervise reporting entities and enforce AML/CTF regulation; and To protect the privacy of individuals and their personal information. The Federation has considered whether these objectives would be affected by the change suggested in next section and has come to the conclusion that it would not materially adversely affect the objectives. The Federation particularly notes the third objective which relates to "striking an appropriate balance between AML/CTF measures and the efficient conduct of business". It is on that basis that the following submission is made. Recommendation: Exemption for certain ASIC licensed credit providers The Federation notes that under sections 247 and 248, the AUSTRAC CEO can exempt certain "low risk reporting entities" from regulatory compliance in certain circumstances. As set out above, it is the opinion of the Federation that providing small amount loans (Small amount Credit Page 6 of 7

8 Contracts and Medium Amount Credit Contracts as prescribed in the NCCP ACT) is a low AML-CTF risk enterprise. The Federation submits that ASIC licensed credit providers who provide loans of $5,000 or less for periods of two years or less should be exempted from the requirement to have a standard AML/CTF program as is required by section 84 of the Anti-Money Laundering and Counter- Terrorism Financing Act It is further submitted that those credit provider could still be required to have an operating under a special AML- CTF program as is envisaged by this section 86 of the Anti-Money Laundering and Counter-Terrorism Financing Act 2006, where the sole or primary purpose is to set out the customer identification procedure is as required under that Act. It is the opinion of the Federation, that it is an unwarranted and excessive requirement for a business such as those operated by the Federation s members to be required to comply with all the checks and balances in a standard AML/CTF program, to record and report on the same, when the matters intended to be monitored or discovered by such a program are able to be monitored outside the program by virtue of the National Credit Act s requirements placed on ASIC licensed credit providers. It is submitted that the aims of the AML/CTF regime as set out in the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 and discussed in the issues paper would not be adversely affected by this change as other obligations under the Act such as the requirement to provide threshold transaction reports, suspicious matter reports and international funds transfer instruction reports would still be maintained. However, the cost to business of maintaining the requirement of a standard AML/CTF program significantly outweighs that which would be lost by removing the obligation. The "balance between AML/CTF measures and the efficient conduct of business" at the moment, it is submitted, is skewed against the efficient conduct of business. Page 7 of 7

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