CA ANZ support the objective to provide relief from lodging reports that provide very little intelligence, striking an appropriate balance between reducing the unnecessary regulatory burden on AFS licensees, while preserving the intention of the reportable situations regime.

To better achieve a sensible balance, between the cost of the process and access to meaningful information for ASIC, we recommend the first proposed parameter is amended to the breach has been rectified within 30 days from when it is first identified, not when the breach occurred.

The joint bodies also recommend that the threshold is increased from $500 to $1,000 and consequently the maximum number of clients is also increased from 5 to 10. We believe that this provides a sensible balance between what is reported to ASIC, the associated costs and the value of the information to ASIC.

The joint bodies also recommend that ASIC report on the effectiveness of the proposed relief 12 months from implementation and through greater detail being included in the annual report on reportable situations; and continue to consider any further opportunities for relief, especially where there is no or minimal consumer financial detriment.

We also believe that there are further civil penalty provisions that could be excluded by the Government from the reportable situations regime, such as the current penalties that apply to fee consent provisions under sections 962R and 962Z of the Corporations Act 2001.