The Joint Associations Working Group (JAWG) welcomes Treasury's consultation package responding to the collapse of Shield and First Guardian. We note the significant consumer harm and loss of  confidence these events have caused across the financial services sector.

The consultation package appropriately recognises that the circumstances surrounding Shield and First Guardian raise a range of interconnected policy issues spanning fund design and governance, distribution practices, licensee and investment governance, compensation arrangements and regulatory oversight.

While the associations represented by the JAWG have taken different individual positions on certain proposals contained in the package, JAWG wishes to draw Treasury’s attention to the policy proposals that have consensus across our organisations.

The JAWG also wishes to draw Treasury’s attention to proposals which have consensus opposition. The JAWG considers that these proposals are not targeted and proportionate to addressing consumer harm, and are outweighed by the unnecessary regulatory burden, additional regulatory complexity, and the significant negative impact on  Australians’ access to financial advice.