Privacy Act 1988 Privacy Amendment (Enhancing … Credit Reporting Code – Statement of...

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Credit Reporting Code – Statement of Consultation

The Credit Reporting Code of Conduct (CR Code) will impact upon a large range of stakeholders and introduce moreprescriptive credit reporting requirements given the more extensive reporting that will be permitted under the amended Actand CR Code. Consumers’ experience of credit reporting will be quite different and external dispute resolution (EDR) schemeswill play an even greater role in the resolution of credit reporting disputes.

Given the significant impact of the CR Code on a large number of stakeholders, the consultation process undertaken todevelop the CR Code has been extensive. It has been designed to identify all relevant stakeholders and provide stakeholderswith adequate opportunity to be involved in the development of the draft CR Code.

ARCA was formally appointed by the Privacy Commissioner to develop the CR Code in December 2012.

Prior to this appointment, ARCA on behalf of its Members had been an active industry advocate, lobbying for reforms to PartIIIA of the Privacy Act 1988, and committed to the introduction of comprehensive credit reporting through the PrivacyAmendment (Enhancing Privacy Protection) Bill 2012 (the Bill).

As part of our advocacy role, ARCA was involved in discussions with stakeholders to develop a process which could support anew code of conduct for the new credit reporting environment, which lead to the publishing of an Issues Paper to testsupport for key ARCA policy positions, and developing a credit reporting framework that supported ARCA’s reform agendaand the delivery of an effective CR Code.

An essential step in this pre-appointment consultation occurred in January 2011 when an independent reviewer (funded byARCA) was appointed to review the development of a new code of conduct in credit reporting.

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With the appointment of ARCA as the “code developer” in December 2012, our capacity to act as an advocate on behalf ofour Members was made more complex with respect to the drafting of the CR Code, as ARCA sought to ensure a balancedCode could be supplied to the OAIC.

ARCA Members remained important and relevant stakeholders, however given the need to consider the broader perspectivesof the wider community and deliver a CR Code that would meet the expectations of the OAIC, ARCA’s role as an industryadvocate has been at odds with the role of code developer that we have undertaken on behalf of the OAIC.

While the code development groundwork undertaken by ARCA prior to formal appointment related to its role as an industryassociation, it is ARCA’s view that any analysis of code consultation ought to incorporate an assessment of work undertakenboth before and after our appointment as code developer. This position is consistent with guidance provided to ARCA by theAttorney General’s Department (AGD) and the OAIC before the tabling of the Bill in November, in the expectation that ARCAwould be appointed to draft the CR Code.

With this in mind, the consultation process has involved the following key activities:

From July 2011, the development of an engagement model for the CR Code with input sought from a wide-range ofstakeholders.

In October 2011, the development of the initial CR Code process and structure which, by late 2011, resulted in theformation of the Code Industry Council (CIC). The CIC was responsible for overseeing the development of the CRCode, with invitations to membership sent by ARCA to wide range of stakeholders.

In March 2012, the release of an issues paper by the Independent Reviewer which then prompted a consultationprocess with a number of stakeholders including EDR schemes, consumer and privacy advocates and industrymembers and associations. This led to the release of an Independent Reviewer’s report in July 2012.

With this groundwork completed, ARCA then appointed Cameronralph Navigator (CRN) as code drafters in September2012. In November 2012, CRN released its code framework document and the first draft of the CR Code to a numberof stakeholders including ARCA Members, CIC members, utilities providers, EDR schemes and consumer and privacyadvocates.

Following the release of this first draft, CRN consulted extensively with stakeholders and, based upon this feedback,released a second draft of the CR Code in January 2013. This draft was provided to ARCA and CIC members, althoughdetails of its contents and amendments were provided by CRN to consumer and privacy advocates in separateconsultations.

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In April 2013 the third draft of the CR Code was made available for a 28 day public consultation. This publicconsultation was advertised in The Australian and the Australian Financial Review, with interested parties directed to aCR Code website established by ARCA. One hundred and thirty-five organisations and individuals subscribed to thewebsite so that they could receive a copy of the draft CR Code.

Mindful of the importance of receiving consumer feedback on the contents of the draft CR Code, ARCA funded thedevelopment of a joint consumer submission (prepared by the Australian Communications Consumer Action Network,the Australian Privacy Foundation, the Consumer Action Law Centre, the Consumer Credit Legal Centre (NSW), theConsumer Credit Legal Service (WA) and Financial Counselling Australia). During the public consultation period, ARCAalso ran a workshop for consumer and privacy advocates where provisions of the draft CR Code were discussed indepth, and advocates were offered an open forum to discuss particular issues arising from the CR Code.

During the consultation process, ARCA identified and consulted with the following groups that were likely to be affected bythe CR Code:

Credit providers within the financial and trade creditors area including individual credit providers and industryassociations namely Abacus – Australian Mutuals, the Australian Bankers’ Association, the Australian Collectors & DebtBuyers Association, the Australian Direct Marketing Association (now the Association for Data-driven Marketing &Advertising), Australian Finance Conference, Australian Institute of Credit Management, Council of Small BusinessOrganisations of Australia, the Financial Services Council, Mortgage & Financial Association of Australia, and theNational Financial Services Federation.

Credit providers and associations within the insurance area including Genworth, Westpac (LMI division), QBEInsurance, the Insurance Council of Australia (ICA), and the Risk Management Institution of Australasia Ltd.

Credit providers within the utilities and telecommunications area including individual supply organisations and industryassociations namely the Communications Alliance, Energy Networks Australia, Energy Retailers Association of AustraliaLimited, Energy Supply Association, and Water Services Association.

Credit reporting bodies including Veda, Experian, Dun & Bradstreet, CreditorWatch and the Tasmanian CollectionService.

EDR schemes including the Financial Ombudsman Service Ltd, the Credit Ombudsman Service Ltd,Telecommunications Industry Ombudsman, and state-based Energy and Water Ombudsmen.

Consumer representatives and privacy advocates including the Australian Council of Social Services, the AustralianPrivacy Foundation, the Consumer Action Law Centre, Consumer Credit Legal Centre NSW, Legal Aid Queensland,

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Wesley Mission, Consumer Action, Australian Communications Consumer Action Network and the Consumer UtilitiesAdvocacy Centre.

Government organisations including the Attorney-General, the Attorney-General’s Department, the Department ofPrime Minister and Cabinet, and the Office of the Australian Information Commissioner.

ARCA and CRN used a variety of methods to consult including public forums and townhalls, interest-group based forums,one-on-one consultation meetings, provision of information through website and email releases, and inviting generalfeedback. The development of the CIC was also utilised as an effective means of gaining feedback. Furthermore, ARCA hasengaged extensively in industry education through “De-mystifying the Bill” and “Privacy and Credit Compliance Solutions”sessions that have occurred throughout Australia in 2012 and 2013. The purpose of this industry education has partly beento ensure that industry knows and understands the changes to credit reporting, and is positioned to provide valuablefeedback about the impact the CR Code will have on current industry practices.

In the below table we have set out a chronological breakdown of the consultation process, as follows:

Key: shaded items represent activity under-taken by ARCA in its capacity as CR Code Developer.

Date Event RelatedDocument

2009 ARCA established credit reporting project to manage the development of industry inputsinto the new Credit Reporting Code of Conduct

12 January2011

Credit Reporting – Independent Review Committee (with members Carolyn Bond (CALC),Andrew Solomon (OAIC), Miles Larbey (ASIC), Sam Ahlin (DPMC) and chaired by CarloCataldo (ARCA) (who did not vote on the outcome)) meet to develop short list of potentialcandidates to undertake an independent review of the credit reporting code of conduct.

Minutes ofmeeting dated12 January2011

19 January2011

ARCA hosts a utilities forum with representatives from AGL, Energy, Power & Water andOrigin to discuss credit reporting reforms, and the participation of industry stakeholders(including utilities companies) in the development of a new credit reporting code ofconduct. Explanation provided of ARCA’s proposed code development process.

Minutes of theARCA –Utilities Forumdated 19January 2011

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ARCA BriefingPack forUtilities

January2011

Independent Reviewer (Chris Connolly) selected by Credit Reporting – IndependentReview Committee to undertake wide community consultation in relation to thedevelopment of the Credit Reporting Code of Conduct.Independent Reviewer paid for by ARCA.

IndependentReview of theCreditReporting Code– Terms ofReference –November2011

February2011

Federal Government (Department of Prime Minister & Cabinet) host a Credit ReportingCode Roundtable attended by representatives of the DPM&C, representatives of theregulator including the Privacy Commissioner, consumer and privacy advocates, industryrepresentatives (including both organisations and industry associations) and ARCA. ARCApresents its proposal to develop the new Credit Reporting Code of Conduct, and obtainsfeedback on this development proposal

CreditReporting CodeRoundtable –ARCA’sproposal todevelop thenew CreditReporting Codeof Conductslide deck

16 March2011

ARCA provides the Senate Standing Committee on Finance and Public Administration adetailed submission in response to the draft of the Australian Privacy AmendmentLegislation – Credit Reporting provisions

Letter fromARCA toSenateStandingCommitteedated 16March 2011

15 July 2011 ARCA provides initial Credit Reporting Code update to Abacus, ActewAGL, AGL Energy,Alinta Energy, Aurora Energy, Ausgrid, Australian Bankers’ Association, AustralianCollectors & Debt Buyers Association, Australian Finance Conference, Australian Power &Gas, Communications Alliance, Country Energy, Dun & Bradstreet, Ergon Energy,Experian, IBM Australia, Integral Energy, Lumo Energy, National Financial Services

Various emailsfrom ARCA tolistedrecipients

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Federation, Optus, Origin Energy, Power & Water, Red Energy, Simply Energy, South EastWater, Telstra, Urban Utilities and Veda.Email recipients are provided with information about developing an engagement model,and the proposed consultation process which:

Engages industry, government, regulators and consumer and privacy advocates Ensures organisations that wish to participate have an opportunity to do so Represents majority and minority positions transparently Provides a draft document to the regulator that has broad acceptance and

understanding across stakeholders Encourages consensus and acknowledges minority and/or dissenting positions

dated 15 July2011

October2011

ARCA develops a CR Code process and structure with a proposed project structure forindustry participation based upon:

Consultation level – creation of a Code Industry Council (CIC) with nominees fromkey industry associations and credit reference agencies to ensure final draft Codehas broadest possible industry support.

Managerial level – formation of a project management committee to ensure workstreams are provided guidance and direction.

Research and proposal development level – creation of a set of Work Streams. Workgroups identified were Communications, Compliance, Code Development,Complaints Handling, Data Standards and Implementation.

To address the broad range of stakeholders affected by proposed redrafting of the CreditReporting Code of Conduct, proposed that independent review conducted through releaseof a consultation paper.“This independent review process will help ensure that individual credit providers, credit reportingagencies, consumer and privacy advocates, regulators, government and other stakeholders have anopportunity to provide feedback and input into the redrafting of the Code.”The Independent Reviewer will then issue a report on the process for the Code application.

ARCA internaldocument“IndustryCreditReportingReformProgram:TransitionalProcess &StructureProposal”,dated October2011

23 October2011

ARCA provides detailed information to Brendan O’Connor MP (then Minister for Privacy andFreedom of Information), the Department of Prime Minister and Cabinet, and the PrivacyCommissioner about the proposed process for reforming the Credit Reporting Code ofConduct

Email fromARCA toBrendanO’Connor MPdated

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23.10.11,8.05pm;Emails fromARCA to PMC,dated23.10.11,7.58pm &8.09pm;Email fromARCA toTimothyPilgrim(PrivacyCommissioner)dated23.10.11,7.56pm

23 October2011

ARCA email to Abacus, Australian Bankers’ Association, Australian Collectors & DebtBuyers Association, Australian Direct Marketing Association, Australian FinanceConference, Australian Institute of Credit Management, Communications Alliance, Councilof Small Business Organisations Australia, Dun & Bradstreet, Energy Networks Australia,Energy Retailers Association of Australia Limited, Energy Supply Association, ExperianAustralia, Financial Services Council, Insurance Council of Australia, Leighton Contractors,Mortgage & Finance Association of Australia, National Financial Services Federation, RiskManagement Institution of Australasia Limited, Tasmanian Collection Service, Veda, WaterServices Association. The email contains information about the credit reporting reforms,the update to the existing Credit Reporting Code and the establishment of the CodeIndustry Council (CIC) process to facilitate the development of the Code. Recipients of theemail are invited to nominate to the CIC and otherwise provide feedback on the reformproposal.

Various emailsfrom ARCA topotential CICorganisations,dated 23October 2011

November2011

ARCA issues Terms of Reference (ToR) for the Independent Reviewer. ToR notes that thereview will have regard to inter alia “the need to ensure comprehensive consultation hasoccurred with key stakeholders, with sufficient information and time provided for feedback

IndependentReview of theCredit

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on key documents”. The ToR specifically identifies the following manner in whichstakeholders can engage in independent review process being:

“Subscribing to the Code Review update service – participants will receive an email noticewhen new documents or versions of the Code are released.

Requesting a direct meeting (phone or face to face) with the Independent Reviewer. Participating in scheduled meetings and workshops (details of these meetings will be listed

on the Review website). Sending comments on documents or submissions on the draft Code to the Independent

Reviewer. Reviewing documentation at the Independent Review website.”

The Independent Reviewer was also tasked with identifying key stakeholders, consultingwith stakeholders regarding the Consultation paper and draft Code, reporting onstakeholder feedback to the CIC.

Reporting Code– Terms ofReference –November2011

November2011

ARCA conducts presentations for the Australian Finance Conference and the InsuranceCouncil of Australia about developing an engagement model for the credit reporting codeof conduct.

“Developing anengagementmodel for thecredit reportingcode ofconduct” slidedeck

Late 2011 Following 23 October 2011 email invitation, the Code Industry Council (CIC) was formedto provide advice and consultation to ARCA for drafting the CR Code. It was formed by ‘optin’.Members of the CIC are:

ARCA Abacus Australian Bankers’ Association (ABA) Australian Collectors and Debt Buyers Association (ACDBA) Australian Finance Conference (AFC) Australian Institute of Credit Management (AICM) Communications Alliance Insurance Council of Australia Mortgage & Finance Association of Australia (MFAA)

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National Financial Services Federation (NFSF) Dun and Bradstreet Experian Veda

The Energy Retailers Association of Australia (ERAA) agreed to join the CIC on 8March 2013.

ARCA chairs the CIC.January2012

ARCA presents at GE conference about credit reporting and responsible lending, providingattendees information about the proposed reforms.

GEpresentationslide deck

1 February2012

Email sent to CIC members proposing first CIC meeting on 23.2.12 Email dated1.2.12

21 February2012

ARCA meeting with Abacus, AMEX, ANZ, Bendigo & Adelaide Bank, CBA, Citi, D&B,Experian, GE, HSBC, ME Bank, NAB, Toyota Finance, Veda, and Westpac in attendance.Matters discussed on the agenda included:

Implementation work stream (Code implementation) is experiencing challenges dueto scope of representatives

Challenges also lie with the varying internal project status

Minutes ofARCAassociationmeeting dated21 February2012

23 February2012

CIC meeting with Abacus, ABA, ACDBA, AFC, AICM, ARCA, Communications Alliance, Dun& Bradstreet, Experian, ICA, MFAA, NFSF, PERC and Veda in attendance. Mattersdiscussed on the agenda:

Overview of the legislative implementation & role of the industry Credit Code development process model Current status Discussion (issues) paper Key CIC decisions

Minutes of CICmeeting dated23 February2012

9 March2012

Letter from CIC (with David Grafton as chairman) to Attorney General Nicola Roxon,supporting credit reporting reforms and offering to provide assistance with delivery ofreforms. Invitation extended to Ms Roxon to address CIC and key organisations at earliestopportunity. Industry endorsement provided by: Abacus – Australian Mutuals, AustralasianRetail Credit Association, Australian Bankers’ Association, Australian Collectors & Debt

Letter fromCIC to HonNicola RoxonMP dated 9March 2012

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Buyers Association, Australian Finance Conference, Australian Institute of CreditManagement, Communications Alliance, Dun & Bradstreet, Experian, Insurance Council ofAustralia, Mortgage & Finance Association of Australia, National Financial ServicesFederation and Veda.

14 March2012

ARCA conducts a presentation for Abacus members about credit reporting and the reformto Part IIIA of the Privacy Act.

Abacus slidedeck

March 2012 ARCA releases issues paper entitled “Updating the 1996 Credit Reporting Code ofConduct”. The purpose of the paper is to summarise the views of members of ARCA, afterCIC feedback, as to what should be considered for inclusion or amendment in thedevelopment of the edited Credit Reporting Code of Conduct.

Issues Paper –Updating the1996 CreditReporting Codeof Conduct –March 2012

26 April2012

CIC meeting with Abacus, ABA, ACDBA, AFC, ARCA, Communications Alliance, Dun &Bradstreet, Experian, ICA, MFAA, NFSF and Veda in attendance. Matters discussed on theagenda:

Changes to CIC membership Review of minutes Update on Bill Independent Review Update – Chris Connolly General matters

Minutes of CICmeeting dated26 April 2012

7 May 2012 CIC meeting with Abacus, ABA, AFC, ARCA, Communications Alliance, Dun & Bradstreet,Experian, ICA, MFAA, NFSF and Veda in attendance. Matters discussed on the agenda:

Changes to CIC membership Review of minutes Review of action items Update on Bill Independent Review Update – Chris Connolly Other business

Minutes of CICmeeting dated7 May 2012

May 2012 ARCA attends a Consumer Advocate Forum hosted by Veda. Representatives from CCLCNSW, Consumer Action Law Centre, Financial Counselling Australia, Legal Aid Queensland,and the Privacy Foundation are in attendance. ARCA discusses the following:

Current status of code development process Key themes of fairness, access, control and equity

Presentationslide deckprepared byARCA, datedMay 2012

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ARCA principles for credit reporting Three pillars for keeping data accurate, up to date and relevant Guidance from the OAIC Credit reporting statutory environment

7 June 2012 CIC meeting with Abacus, ABA, AFC, ARCA, Communications Alliance, Dun & Bradstreet,Experian, ICA, MFAA, NFSF and Veda in attendance. Matters discussed on the agenda:

Review of minutes Review of action items Closed items Code drafters CIC Chair Representation Presentation – Richard Glenn, AGD Revised code development process Other business

Minutes of CICmeeting dated7 June 2012

19 June2012

ARCA meeting with Abacus, AMEX, ANZ, Bendigo & Adelaide Bank, Capital Finance, CBA,Citi, Experian, GE, ME Bank, NAB, Suncorp, and Toyota Finance in attendance.inattendance. Matters discussed on the agenda included:

Account Management issue – Australian context, account management may belimited, may be one of the issues taken to the submission hearings

CR Code consultation process discussed Request for proposal for Code Drafter – reviewed by the CIC, identified 4 potential

Code Drafters from the CIC including 2 nominations from ARCA. Process of selectionfor ARCA to work through the submissions, engage with the potential drafters.

Minutes ofARCAAssociationmeeting dated19 June 2012

July 2012 Independent Reviewer issues first report of the Independent Review of the new CreditReporting Code of Conduct – the purpose of the review was to seek stakeholder feedbackin relation to issues identified in the March 2012 issues paper. Stakeholders consultedwere:

Abacus Australian Council of Social Services Australian Privacy Foundation Commonwealth Bank Consumer Action Law Centre Consumer Credit Legal Centre NSW

First Report –Independentreview of theCreditReporting Codeof Conduct –July 2012

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Dunn and Bradstreet Energy and Water Ombudsman NSW Energy and Water Ombudsman Victoria Experian Financial Ombudsman Service Genworth Insurance Council of Australia Office of the Australian Information Commissioner Optus QBE Insurance Telecommunications Industry Ombudsman Veda Advantage Westpac (LMI section only).

Report to be used by ARCA to commission a draft Code with more detailed stakeholderconsultation required as part of the Code development.

July 2012 ARCA conducts a presentation for Citi about the credit reporting code and the reform toPart IIIA of the Privacy Act.

CreditReporting &Part IIIA slidedeck

5 July 2012 CIC meeting with Abacus, ABA, ACDBA, AFC, AICM, ARCA, Communications Alliance, Dun& Bradstreet, Experian, ICA, MFAA, NFSF and Veda in attendance. Matters discussed onthe agenda:

Review of minutes Submission process & issues Committee hearings Conflict of interest policy RFP update

Minutes of CICmeeting dated5 July 2012

6 July 2012 ARCA hosts a “Demystifying the Bill” forum in Melbourne. Forum is intended to provideinformation about the changes to credit reporting, and facilitate the provision of feedbackabout these changes. Attendees include ANZ, CBA, Citi, GE, HSBC, NAB, Westpac, Veda.

“Demystifyingthe Bill” slidedeck

16 August2012

ARCA hosts a “Demystifying the Bill” forum in Sydney. Forum is intended to provideinformation about the changes to credit reporting, and facilitate the provision of feedback


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about these changes. Attendees include Amex, GE, CBA, Citi, D&B, HSBC, Toyota,Westpac.

17 August2012

ARCA hosts a “Demystifying the Bill” forum in Perth. Forum is intended to provideinformation about the changes to credit reporting, and facilitate the provision of feedbackabout these changes. Attendees include representatives from Abacus members


18 August2012

ARCA hosts a “Demystifying the Bill” forum in Perth, for 20 staff from BankWest. Forum isintended to provide information about the changes to credit reporting, and facilitate theprovision of feedback about these changes.


22 August2012

ARCA hosts a “Demystifying the Bill” forum in Melbourne. Forum is intended to provideinformation about the changes to credit reporting, and facilitate the provision of feedbackabout these changes. Attendees include CBA, D&B, Experian, GE, NAB, Suncorp.


September2012

ARCA conducts a presentation for Citi about the credit reporting code and the reform toPart IIIA of the Privacy Act.

CreditReporting &Part IIIA slidedeck

September2012

ARCA attends the Credit Law Conference and provides a presentation about creditreporting and the proposed reforms to the credit reporting code of conduct.

Credit LawConferenceslide deck

3 September2012

CIC meeting with Abacus, ABA, ACDBA, AFC, AICM, ARCA, Communications Alliance, Dun& Bradstreet, Experian, Insurance Council of Australia and MFAA in attendance. Mattersdiscussed on the agenda:

Review of minutes Legislative update Independent review report Code drafting Data standard General matters

Minutes of CICmeeting dated3 September2012

5 September2012

CRN appointed CR Code drafters by ARCA Board, after proposal from CIC. Email fromARCA to CRNdated 5.09.12,9.52am

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18September2012

ARCA meeting with AMEX, ANZ, Bendigo & Adelaide Bank, CBA, Citi, Experian, GE, HSBC,NAB, Suncorp, Veda, and Westpac in attendance. Matters discussed on the agendaincluded:

Code Drafters appointed – Cameron ralph Navigator. Initial meetings conductedwith ARCA. Contracts to be finalised on 25/9

Minutes ofARCAAssociationmeeting dated18 September2012

19September2012

ARCA hosts a “Demystifying the Bill” forum in Melbourne, for 22 staff from Experian.Forum is intended to provide information about the changes to credit reporting, andfacilitate the provision of feedback about these changes.


26September2012

Consumer Education Roundtable chaired by the AGD, hosted by ARCA in Sydney.Attendees: ABA, Abacus, ACCAN, AFC, AGD, AICM, ARCA, Care FCS, CCL NSW,Communications Alliance, Consumer Action, D&B, Experian, Financial CounsellingAustralia, Legal Aid QLD, OAIC, Optus, Telstra, Veda.

Presentations by Richard Glenn (Assistant Secretary, Business and Information LawBranch, Attorney General’s Department) and Timothy Pilgrim (Privacy Commissioner)about the development of a consumer education campaign for credit reporting reforms.Open discussion took place about credit reforms and interplay with consumer education.

27September2012

CIC meeting with ABA, ACDBA, AICM, ARCA, Communications Alliance, Dun & Bradstreet,Experian, ICA, MFAA and NFSF in attendance. Matters discussed on the agenda:

Review of minutes Review of action items Legislative update AGD Consumer Education Code Drafting Update General business

Minutes of CICmeeting dated27 September2012

28September2012

ARCA hosts a “Demystifying the Bill” forum in Melbourne, for 21 staff from NAB. Forum isintended to provide information about the changes to credit reporting, and facilitate theprovision of feedback about these changes.


October2012

ARCA updates CR Code process and structure (drafted initially in October 2011) whichcontains a similar structure to Code development, with ARCA in the role of overallmanagement of the CR Code development project and with stakeholder consultation to be

ARCA internaldocument“ARCA CreditReporting

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completed by the CR Code drafters. In particular, it is identified that the Code drafters areto undertake the following activities:

“Identification of stakeholders Stakeholder consultation related to Consultation Paper and draft Code Development of stakeholder consultation template and strategy Provision of report into stakeholder feedback on Consultation paper and draft Code”

Furthermore, the consultation structure proposed to be implemented for effectiveengagement and endorsement of the reform process is as follows:

ReformProgram:TransitionalProcess &StructureProposal”,dated October2012

3 October2012

ARCA hosts a “Demystifying the Bill” forum in Melbourne, for 14 staff from ANZ. Forum isintended to provide information about the changes to credit reporting, and facilitate theprovision of feedback about these changes.


9 October2012

Preliminary consultation between CRN and Australian Collectors and Debt BuyersAssociation – discussion of concerns and provision of information about consultationprocess

CRNConsultationrecord

11 October2012

Preliminary consultation between CRN and ANZ – discussion of key CR Code principles andrequirements for ANZ


12 October2012

Preliminary consultation between CRN and ICA – discussion of concerns and requirementsfor CR Code


15 October2012

Preliminary consultation between CRN and Australian Bankers’ Association – discussion ofimpact of CR Code on ABA members, CR Code format and consultation process


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16 October2012

ARCA meeting with AMEX, ANZ, Bendigo & Adelaide Bank, CBA, Citi, Experian, GE, HSBC,NAB, Suncorp, Veda and Westpac in attendance. Matters discussed on the agendaincluded:

Ongoing AGD contact to discuss ‘Australia link’ Code drafters are moving quickly Compliance framework discussion

Minutes ofARCAAssociationmeeting dated16 October2012

17 October2012

Preliminary consultation between CRN and CIC Chairman – discussion of CIC, consultationprocess, CR Code framework and use of working groups to facilitate feedback


17 October2012

Preliminary consultation between CRN and CBA – discussion of CR Code framework, andrequirements for the CR Code


17 October2012

Preliminary consultation between CRN and Australian Finance Conference – discussion ofconsultation process (townhall forum), gap analysis with current Code and proposedlegislative requirements, requirements of commercial financiers


18 October2012

Meeting between CRN, ARCA and OAIC, including the Privacy Commissioner Email fromOAIC to CRNdated 8.10.12,4.11pm

25 October2012

CIC meeting with Abacus, ABA, ACDBA, AFC, AICM, ARCA, Communications Alliance,Experian, ICA, NFSF and Veda in attendance. Matters discussed on the agenda:

Review of minutes Review of action items Privacy Act Amendment Bill CR Code drafting update General business

Minutes of CICmeeting dated25 October2012

30 October2012

Preliminary consultation between CRN and Experian – discussion of concerns regarding CRCode, industry code, ARCA’s role.


31 October2012

ARCA senior executive forum attended by ARCA, CRN, ABA, Abacus, AFC, ANZ, Bank ofQueensland, Bendigo & Adelaide Bank, CBA, Citi, Dun & Bradstreet, Experian, GE, HSBC,ME Bank, NAB, Toyota Finance and Westpac – discussion of CR Code process andconsultation requirements


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ARCA email toSeniorExecutiveforum dated30.10.12,8.49pm

31 October2012

ARCA hosts a “Demystifying the Bill” forum in Melbourne. Forum is intended to provideinformation about the changes to credit reporting, and facilitate the provision of feedbackabout these changes. Attendees include representatives from Abacus members


1 November2012

Preliminary consultation between CRN, Communications Alliance, Telstra, Optus and VHA –discussion of telecommunications requirements for CR Code, draft framework


1 November2012

Preliminary consultation between CRN and CALC consumer advocates – discussion ofconsumer issues in operation of CR Code, discussion of consultation requirements


2 November2012

ARCA hosts a “Demystifying the Bill” forum in Adelaide. Forum is intended to provideinformation about the changes to credit reporting, and facilitate the provision of feedbackabout these changes. Attendees include representatives from Abacus members


7 November2012

Preliminary consultation between CRN and Abacus – discussion of interests of Abacusmembers in the CR Code process


9 November2012

ARCA provides CIC & ARCA Members with the Credit Reporting Code Framework reportdrafted by CRN. ARCA advises this document has been shared with ARCA Members andconsumer advocates. The document will be circulated with broader industry on 13November 2012, to gauge reaction and issues from industry and to facilitate feedbackthrough a broader ‘town hall’ meeting

ARCA email toCIC membersdated 9.11.12,4.28pm

12November2012

Preliminary consultation between CRN and the Privacy Foundation – discussion of CR Codeconsultation process, language of CR Code, discussion of CR Code content and principles


14November2012

ARCA hosts a “Demystifying the Bill” forum in Sydney. Forum is intended to provideinformation about the changes to credit reporting, and facilitate the provision of feedbackabout these changes. Attendees include representatives from Abacus members


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16November2012

ARCA hosts a “Demystifying the Bill” forum in Brisbane. Forum is intended to provideinformation about the changes to credit reporting, and facilitate the provision of feedbackabout these changes. Attendees include representatives from Abacus members


16November2012

Provision of CRN CR Code framework documents to all major stakeholders (detailedbelow). In this framework document, CRN identifies that there will be 2 key phases ofconsultation:

1. Code framework consultation in November 2012; and2. First draft of the CR Code in February 2013.

CRN proposed to use consultation methods including ‘town hall’ industry forums andtargeted consultation with particular stakeholder groups including a workshop withconsumer and privacy advocates. CRN highlighted that ‘testing’ of provisions with PrivacyCommissioner and privacy and consumer advocates would be essential to the consultationprocess – given the OAIC would ultimately have to be satisfied the proposed Code wasconsulted widely and genuinely.

CRN email toOAIC, dated16.11.12,2.21pm

ConfidentialCRN documententitled“ProposedCreditReporting CodeFramework”,November2012

16November2012

ARCA provides ‘Utilities Industry Stakeholders’ (representatives from Ergon, ACTEWAGL,Lumo Energy, Power Water, Country Energy, Aurora Energy, Alinta, Origin Energy, IBM,Urban Utilities, Australian Power & Gas, Red Energy, Simply Energy, South East WaterLimited, Integral Energy and Energy) with the Credit Reporting Code Framework reportdrafted by CRN. Invitation extended to attend a public meeting on 28 November 2012(Melbourne) and 29 November 2012 (Sydney)

ARCA email toutilitiesindustrystakeholders,dated16.11.12,1.05pm

16November2012

ARCA provides the Council of Small Business Organisations Australia (COSBOA) with theCredit Reporting Code Framework report drafted by CRN. Invitation extended to attend apublic meeting on 28 November 2012 (Melbourne) and 29 November 2012 (Sydney)

ARCA email toCOSBOA,dated16.11.12,12.55pm

16November2012

ARCA provides the Privacy Commissioner, the ACCC, Australian Communications andMedia Authority (ACMA) and ASIC with a copy of the Code Development Framework andrequests each organisation to confirm whether it is necessary for ARCA and the Codedrafters to meet to discuss the framework and the development of the Codes

ARCA email tothe PrivacyCommissioner,ACCC, ACMA,

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ASIC dated16.11.12,2.13pm

16November2012

ARCA provides ‘Ombudsman representatives and consumer advocates’ (AustralianCommunications Consumer Action Network, CCLC NSW, Choice, Consumer Action,Consumer Utilities Advocacy Centre, COSL, Energy Networks Association, ERAA, ESAA,EWON, FOS, Legal Aid Queensland, Privacy Foundation, Public Interest Advocacy Centre)with the Credit Reporting Code Framework report drafted by CRN. Invitation extended toattend a public meeting on 28 November 2012 (Melbourne) and 29 November 2012(Sydney)

ARCA email toOmbudsmanrepresentativesand ConsumerAdvocates,dated16.11.12,1.40pm

16November2012

ARCA emails its Members (Abacus, AMEX, Bank of Queensland, Capital Finance, CBA, Citi,Dun & Bradstreet, Experian, GE, HSBC, ME Bank, NAB, Toyota, Veda, and Westpac) & theCIC with details of the two upcoming industry forums on 28 and 29 November 2012 andurges them to extend the invitation to all relevant business representatives and teams, sothat a better understanding can be gained of the framework and objectives proposed bythe code drafters

ARCA email tomembersdated16.11.12,12.51pm

ARCA email toCIC dated16.11.12,12.39pm

20November2012

ARCA meeting with Abacus, AMEX, ANZ, Bendigo & Adelaide Bank, CBA, Citi, D&B,Experian, GE, HSBC, ME, NAB, Suncorp, Veda, Westpac in attendance. Matters discussedon the agenda included:

Principles of Reciprocity Consultation completed by CRN. Language to be re-worked to ensure consistency

Minutes ofARCAassociationmeeting dated20 November2012

21November2012

CIC meeting with Abacus, ABA, ACDBA, AFC, AICM, ARCA, Communications Alliance, Dun& Bradstreet, Experian, ICA, MFAA, NFSF, Veda and the Privacy Commissioner inattendance. Matters discussed on the agenda:

Credit reporting presentation – Timothy Pilgrim Review of minutes Review of action items

Minutes of CICmeeting dated21 November2012

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Legislative update Draft Code update Consumer Education

22November2012

ARCA releases first draft of the CR Code to ARCA Members (Abacus, AMEX, ANZ, Bank ofQueensland, BankWest, Bendigo & Adelaide Bank, Citi, Commonwealth Bank of Australia,Dun & Bradstreet, Experian, GE, HSBC, National Australia Bank, Suncorp, Toyota Finance,Veda, Westpac)

Email fromMatt Gijselman(ARCA) toARCAmembers,dated22.11.12,4.12pm

27November2012

CRN releases first draft of the CR Code to consumer and privacy advocate representatives(Australian Communications Consumer Action Network, Consumer Action Law Centre,Consumer Credit Legal Centre NSW, Consumer Utilities Advocacy Centre, FinancialCounselling Australia, Legal Aid Queensland, Privacy Foundation and Wesley Mission)

Email fromCRN toconsumer &privacyadvocates,dated27.11.12,5.45pm

28November2012

Townhall meeting held in Melbourne with attendees from AGL, ANZ, ARMS Group, Dun &Bradstreet, Experian, GE, Lumo Energy, NAB, Power & Water and Red Energy.Presentation about and discussion of Framework Consultation Paper including proposed CRCode drafting principles and structure/format.

29November2012

Attendance by CRN at EWON Consultative Council to discuss design consultation/first draftof the CR Code


29November2012

Telephone consultation between CRN and Westpac regarding first draft of the CR Code CRNConsultationrecord

29November2012

Townhall meeting held in Sydney with attendees from ABA, ACDBA, AFC, Allianz, ARMSGroup, BankWest, Capital Finance, CBA, Communications Alliance, Dun & Bradstreet,Ergon, Experian, Insolvency Management Services, Locke Pty Ltd, MFAA, NFSF, Power &

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Water, Suncorp, Veda, Vodafone and Westpac. Presentation about and discussion ofFramework Consultation Paper including proposed CR Code drafting principles andstructure/format.

30November2012

Consumer Advocates Reference group attended by Consumer Action Law Centre, Legal AidQueensland, Financial Counselling Australia, Australian Communications Consumer ActionNetwork and CRN, discussion of first draft of CR Code and consumer representatives’concerns with specific provisions of the draft Code

CRNConsultationrecordMinutes ofmeeting ofConsumer andPrivacyAdvocatesReferenceGroup, dated30.11.12

2 December2012

CRN provided the amended version of the draft CR Code to the OAIC, with a view toseeking OAIC comments on content of the draft

Email fromCRN to OAICdated 2.12.12,12.23pm

3 December2012

EDR Schemes townhall attended by CRN, EWON, EWOQ, FOS, and the TIO – Discussion ofearly version of CR Code including whether EDR alternative will be available for all CPs andEDR ramifications of correction requests.

CRNConsultationRecord

13December2012

Consultation between ARCA, CRN and the Privacy Commissioner to discuss the initial draftof the CR Code

Internal emailfrom CRN toARCA dated13.12.12,1.52pm

14December2012

Consultation between CRN and the Privacy Foundation to discuss the initial draft of the CRCode

CRNConsultationRecord

20December2012

CIC meeting with Abacus, ABA, ACDBA, AFC, AICM, ARCA, Communications Alliance, Dun& Bradstreet, Experian, ICA, MFAA, NFSF and Veda in attendance. Matters discussed onthe agenda:

Minutes of CICmeeting dated

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Review of minutes Review of action items CRN Code update Draft Privacy Code review

20 December2012

20December2012

Australian Privacy Commissioner, Mr Timothy Pilgrim, formally requests ARCA develop aCR Code and apply for the code to be registered

Letter fromOAIC to ARCAdated 20.12.12

20December2012

CIC provided with first full draft of the CR Code

7 January2013

Consultation between CRN and GE – discussion of drivers for CR Code, issues underdevelopment


17 January2013

Consultation between CRN and David Grafton (chair of the CIC) – discussion of CICprocess, provision of feedback from CIC members


25 January2013

Release of draft CR Privacy Code version 2.0 (the CR Code) and the draft CR IndustryCode version 1.3 to ARCA members and the CIC. Also provided Consultation draft report,draft Framework Preamble, and the Privacy Code with and without mark ups

Email fromDamian Paull(ARCA) to CICmembersdated25.01.13,10.42pmEmail fromARCA toindividualARCAmembers,dated25.01.13,10.39pm

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29 January2013

Further follow up invitation from ARCA to Tasmanian Collection Service (Tascol) to viewthe draft CR Code, receive a briefing on the new Code framework and/or join the CICmoving forward

Email fromMatt Gijselman(ARCA) toPeter Cretan(Tascol), dated29.01.13,3.36pm

31 January2013

Consultation between CRN and Experian – discussion of legislative expectations of the CRCode, whether the draft CR Code achieves appropriate balance, some technical issues


February2013

CRN reports on the consultation process for the initial drafts of the CR Code and IndustryCode. It anticipates a 6 week consultation period, with industry forums to be hosted inSydney, Melbourne and Brisbane in early to mid-March, and a separate forum held withconsumer and privacy advocates.

ConfidentialCRN documententitled “CreditReportingPrivacy Codeand CreditReportingIndustry Code– ConsultationDrafts”, datedFebruary 2013

1 February2013

OAIC provided with ARCA internal legal advice regarding draft provisions of the CR Coderelating to audits, corrections and complaints

Email fromCRN to OAIC,dated 1.02.13,3.41pm

1 February2013

ARCA hosts a teleconference with ARCA Members to discuss the draft CR Code Internal ARCAcalendar entry,dated 01.02.13

6 February2013

Consultation between CRN and ABA, Abacus and AFC – discussion of process, role of CIC,position of smaller credit providers


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7 February2013

Consultation between CRN and Communications Alliance – discussions oftelecommunications members views regarding the CR Code


7 February2013

CIC meeting with Abacus, ABA, ACDBA, AFC, AICM, ARCA, Communications Alliance, Dun& Bradstreet, Experian, ICA, NFSF and Veda in attendance. Matters discussed on theagenda:

Review of minutes Draft code review and discussion

Minutes of CICmeeting dated7 February2013

13 February2013

AICM and ARCA host Privacy & Credit Compliance Solutions (PCCS) forum in Brisbanefocussing on credit reporting and discussing:

Changes to Part IIIA Impact and considerations of credit reporting changes for providers Legislative framework Status update regarding the CR Code The consultation process and how to participate and make a submission

Attendees include: Akzo Nobel Pty Ltd, ALM, Data # 3, Dynamic Supplies Pty Ltd,Endeavour Foundation, Fisher & Paykel Australia Pty Ltd, Gadens Lawyers, HansonConstruction Materials Pty Ltd, Hyne & Son Pty Ltd, Integria Health Care (Australia) PtyLtd, IOR Energy, Patane Lawyers, Playfair Consulting, RPS Australia Pty Ltd, SPARAustralia Ltd, Tillys Crawler Parts Pty Ltd

PCCS slidedeck

15 February2013

AICM and ARCA host Privacy & Credit Compliance Solutions (PCCS) forum in Sydneyfocussing on credit reporting and discussing:


Attendees include: Actron Engineering Pty Ltd, Alcon Labs, Austral Wright Metals, AvnetTechnology Solutions, Baiada Poultry Pty Ltd, Bauer Media Limited, Brickworks BuildingProducts, CHEP Australia, Coates Hire, Hume Plasterboard Pty Ltd, Impact FinancialServices, Onesteel Trading Pty Ltd, Rocla Pty Ltd, Seven Network (Operations) Limited,Shield Mercantile Pty Ltd, SLR Consulting, Star Track Express Pty Ltd, Veda, YokogawaAustralia Pty Ltd, Zip Heaters (Aust) Pty Ltd

PCCS slidedeck

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15 February2013

Consultation between CRN and Consumer Law Action Centre Victoria – discussion ofconsumer priorities for the draft CR Code


19 February2013

Consultation between CRN and NAB – discussion of written feedback provided in relationto the 25 January 2013 draft CR Code


19 February2013

ARCA meeting with Abacus, ANZ, Capital Finance, CBA, Citi, D&B, Experian, GE, HSBC, MEBank, NAB, Suncorp, Veda and Westpac in attendance in attendance. Matters discussed onthe agenda included:

10 organisations provided feedback on draft CR Code by 11 February. Extensionprovided until 8 March.

Common approach for obtaining historical data into the system was discussed. Audits – direct result of the OAIC, CR Code current drafting may be contrary to the

spirit of the Act. Correction and Complaints – unsuccessful attempt for the CR Code to deal with both

through “referrals” to the holding/ owning CP or CRB. Code drafting update raised many topics.

Minutes ofARCAassociationmeeting dated19 February2013

20 February2013

Consultation between CRN and GE - discussion of written feedback provided in relation tothe 25 January 2013 draft CR Code


21 February2013

AICM and ARCA host Privacy & Credit Compliance Solutions (PCCS) forum in Melbournefocussing on credit reporting and discussing:


Attendees include: BP Australia Pty Ltd, Bunzl Outsourcing Services Ltd, Carpet CourtAustralia Ltd, Cryovac Australia Pty Ltd, Davey Water Products Group, Fuji Xerox AustraliaPty Ltd, GWA Group Limited, Leibler Yavneh College, Mars Australia Pty Ltd, Mercedes-Benz Australia/Pacific Pty Ltd, Penrite Oil Company, RACV – Finance, Scottish PacificBenchmark Group, Star Track Express, Tasco Inland Australia Pty Ltd, Whirlpool AustraliaPty Ltd

PCCS slidedeck

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21 February2013

Consultation between CRN and Westpac - discussion of written feedback provided inrelation to the 25 January 2013 draft CR Code


22 February2013

Consultation between CRN and Citi - discussion of written feedback provided in relation tothe 25 January 2013 draft CR Code


27 February2013

ARCA requests extension of time to submit CR Code for approval from 19 April 2013 to 1July 2013

Letter fromARCA to OAICdated 27February 2013

1 March2013

ARCA provides Tasmanian Collection Service (Tascol) with OAIC letter appointing ARCA todraft the Code, ARCA seeks feedback from Tascol about the draft CR Code including anoffer to travel to Tasmania to discuss

Email fromMatt Gijselman(ARCA) toPeter Cretan(Tascol), dated01.03.13,6.07pm

1 March2013

Consultation between CRN and ANZ - discussion of written feedback provided in relation tothe 25 January 2013 draft CR Code


1 March2013

Consultation between CRN and Veda - discussion of written feedback provided in relationto the 25 January 2013 draft CR Code


4 March2013

Consultation between CRN and Experian - discussion of written feedback provided inrelation to the 25 January 2013 draft CR Code


7 March2013

Consultation between CRN and Experian - discussion of written feedback provided inrelation to the 25 January 2013 draft CR Code


8 March2013

ARCA release its Summer 2013 edition of the Credit Report which is available on its publicwebsite and also to the following subscribers: AAMC Training, ABA, Abacus, ACDBA, AFC,AGD, AICM, AMEX, ANZ, ASIC, BankWest, Bendigo Adelaide Bank, Bank of Queensland,Carlo Cataldo, CBA, Chris Richardson, Citi, Collection House, Communications Alliance,

The CreditReport

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Consumer Action, COSL, CreditorWatch, Dun & Bradstreet, ERAA, EWON, Experian, FirstAvenue, GE, Genworth, HSBC, HWL Ebsworth, ICA, InterThinx, KL Gates, Langes, LegalAid Qld, Lloyds International, Locke, ME Bank, MFAA, NAB, NFSF, OAIC, Optus, PERC,Privacy Foundation, Queenslanders, Sarah Mudd, Tasmanian Collection Services, Telstra,Toyota, Veda, Westpac.Article topics include:

The Privacy Bill’s passed – now what? Experts comment on the Bill passing New CR Code takes shape Consumer Education campaign gathers steam Understanding reciprocity Financial exclusion

14 March2013

Consultation between CRN and Suncorp - discussion of written feedback provided inrelation to the 25 January 2013 draft CR Code


19 March2013

ARCA meeting with Abacus, ANZ, Bendigo & Adelaide Bank, Capital Finance, CBA, Citi,D&B, Experian, GE, NAB, Suncorp, Veda and Westpac in attendance. Matters discussed onthe agenda included:

CR Code draft released Status was provided on CR Code development Board meeting on 28th March to prepare draft code for consultation

Minutes ofARCAassociationmeeting dated19 March 2013

21 March2013

Consultation between CRN and Consumer Credit Legal Centre NSW – discussion ofconsumer feedback, consultation process going forward and finalisation of CR Code


21 March2013

CIC meeting with ABA, ACDBA, AFC, AICM, ARCA, Communications Alliance, Dun &Bradstreet, ERAA, Experian, ICA, NFSF, Veda and CRN in attendance. Matters discussed onthe agenda:

Review of minutes Action items CR Code discussion CRN CR update Industry Code General business

Minutes of CICmeeting dated21 March 2013

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5 April 2013 Credit Reporting Code of Conduct made available for public submission, with submissionsto be provided by 5 May 2013.Advertisements placed in The Australian (page 28) and the Australian Financial Review(page 22) calling for public submissions and directing the public to the ARCA website forfurther information on the draft CR Code

The Australian,page 28, dated5 April 2013The AustralianFinancialReview page22, dated 5April 2013

8 April 2013 ARCA Consumer Advocate Forum hosted in Melbourne. Agenda items were as follows: CR Code development process update Consumer research outcomes Consumer education and notification Role of ARCA in industry education Implementation issues Corrections & complaints in the new environment Default definitions Industry code issues Open forum for advocates

Invitations for the forum were sent to: Australian Communications Consumer Action Network Brotherhood of St Laurence Choice Civil Liberties Australia Consumer Action Consumer Credit Legal Centre NSW Consumer Credit Legal Service (WA) Inc Consumer Utilities Advocacy Centre Financial Counselling Australia Legal Aid Queensland Public Interest Advocacy Centre The Australian Privacy Foundation

Agenda –ARCAConsumerAdvocateForum, dated 8April 2013

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9 April 2013 AICM and ARCA host Privacy & Credit Compliance Solutions (PCCS) forum in Adelaidefocussing on credit reporting and discussing:


Attendees include: Anderson Solicitors, Brice Metals Australia Pty Ltd, FMG Engineering,Walker Stores (Pty) Ltd, NCI (Brokers) Pty Ltd, Angas Securities Pty Ltd, Adelaide FuelDistributors

PCCS slidedeck

11 April2013

Request by Consumer Credit Legal Centre (NSW) to ARCA to fund a joint consumersubmission for the Credit Reporting Code Consultation

Letter fromCCLC to ARCAdated 11 April2013

12 April2013

AICM and ARCA host Privacy & Credit Compliance Solutions (PCCS) forum in Melbournefocussing on credit reporting and discussing:


Attendees include: ALM, ANZ, Australian Pharmaceutical Industries Ltd, CCP CompositesAust, Cisco Systems Capital (Australia) P/L, Fletcher Insulation, GlaxoSmithKline Aust PtyLtd, H.J Heinz Co. Australia Ltd, Hardings Hardware Pty Ltd, Mitsubishi Australia Ltd,Moffat Pty Ltd, Petrogas Pty Ltd, RACV Finance Limited, realestate.com, Scalzo FoodIndustries

PCCS slidedeck

12 April2013

ARCA agrees to funding joint consumer submission for the Credit Reporting CodeConsultation

Email fromARCA to CCLCdated12.04.13,3.32pm

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19 April2013

ARCA meeting with Abacus, AMEX, ANZ, Bendigo & Adelaide, CBA, Citi, D&B, Experian,HSBC, ME, NAB, Toyota, Suncorp, Veda and Westpac in attendance. Matters discussed onthe agenda included:

Draft code released for public consultation on 5 April Credit Repair Agencies published media release for “red alert” for CR Code

Consultation process Discussions on further steps in relation to consultation process

Minutes ofARCAassociationmeeting dated19 April 2013

24 April2013

AICM and ARCA host Privacy & Credit Compliance Solutions (PCCS) forum for ToyotaFinance focussing on credit reporting and discussing:


PCCS slidedeck

1 May 2013 EDR scheme forum attended by CRN, EWON, FOS, and the TIO – public consultationregarding draft CR Code – discussion of timeframe, regulations and industry code.Discussion of particular CR Code provisions and EDR scheme feedback in relation to thoseprovisions.


2 May 2013 Consultation between CRN and Communications Alliance and Optus regarding draft CRCode and submissions in response to the CR Code


5 May 2013 Deadline for providing submissions in response to draft CR Code closes5 April 2013to 5 May2013

ARCA provided a website form fororganisations/individuals to input theirdetails and receive a copy of the draft CRCode for review. The followingorganisations/individuals inputted theirdetails and were provided a copy of thedraft CR Code:

ABA Abacus AFN Corporate Finance AICM

Hume Building Society Hunt & Hunt Hunter HWL Ebsworth iComply IMB Ltd Information Integrity Solutions P/L ING Insurance Council of Australia Investment Dynamics Pty Ltd John S Johnson (JP)

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Allens Andrew Kalavritinos Andrew Taylor ANZ ARCA Ashurst Australia ASIC Australian Banking and Finance Australian Collectors & Debt Buyers

Association Australian Finance Conference Banking Day Bankwest Bartier Perry Baycorp Becker Commercial Services Bendigo & Adelaide Bank Limited Bluestone group Calvert Duffy Cameron Ralph CASA CBA CCMC Clayton Utz Collection House Limited Community CPS Australia Limited Community First Credit Union Consumer Action Law Centre Cooper Grace Ward lawyers Corrs Chambers Westgarth Credit Corp Group Limited Credit Ombudsman Service Ltd Credit Repair Australia

Karl Balian & Co Pty Ltd Kelly & Co. Lawyers Keystart KPMG Langes Lawyers Liberty Financial M+K Lawyers Macquarie Bank Maritme Mining Power Credit Union Mastercard McKinsey&Company ME Bank Min-it Software Minter Ellison Lawyers Moffat Pty Ltd Momentum Energy MTA Credit Partners National Australia Bank Limited Nimble Nissan Financial Services Pty Ltd Norton Rose nymity OAIC Once Credit Pty Limited Optus Pty Ltd. P&N Bank PERI Australia Pty Limited Peter Clarke Petrogas Pty Ltd PRFinance Group Limited QBE Lenders Mortgage Insurance QT Mutual Bank Queenslanders Credit Union Ltd

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Credit Repair Industry Association ofAustralasia

Credit Suisse CRG CUA Daniels Bengtsson Pty Limited DBCDE DibbsBarker Donaldson Walsh Dun & Bradstreet Dynamic Supplies Energy and Water Ombudsman

Victoria (EWOV) Energy Retailers Association of

Australia Equifax Ernst & Young Experian Australia FCAQ Finance Industry Delegation Financial Ombudsman Service First Choice Credit Union Fitch Ratings Ltd Foster Nicholson Jones Lawyers Gadens Lawyers GE Capital General Cable Australia Pty Ltd Gilbert + Tobin Lawyers Greater Building Society Ltd Hall & Wilcox lawyers Herbert Smith Freehills Holley Nethercote Solicitors HomeStart Finance

Rabobank RAC Finance Ltd RACQ Operations Pty Ltd Red Energy RESIMAC Rod Davidson Russell Kennedy Lawyers S2P2 Strategies Simply Energy Suncorp Bank Teachers Mutual Bank Telecommunications Industry

Ombudsman Telstra The Rock Toyota Finance Australia Limited Ultradata Australia University of Queensland Veda Victorian Mortgage Group Walker Stores Pty ltd WAW Credit Union Westpac Banking Corporation Yamaha Motor Finance Australia Pty

Ltd Yoogalu Pty Ltd

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HopgoodGanim8 May 2013 AICM and ARCA host Privacy & Credit Compliance Solutions (PCCS) forum in Perth

focussing on credit reporting and discussing: Changes to Part IIIA Impact and considerations of credit reporting changes for providers Legislative framework Status update regarding the CR Code

Attendees include: Automotive Holdings Group Limited, Brooke Bird, BGC (Australia) PtyLtd, CCI WA, Hanley Poynton Ltd, Kerry Holden, Quick Service Restaurant Holdings, RandTransport (1986) Pty Ltd, Ravensdown Fertiliser Co-operative, Rusty Surfboards Pty LtdWest Australian Newspapers Ltd

PCCS slidedeck

13 May 2013 Consultation between CRN and Consumer and privacy representatives discussing draft CRCode and issues that consumer and privacy representatives were proposing to raise intheir submission


21 May 2013 ARCA meeting with Abacus, AMEX, ANZ, CBA, Citi, D&B, Experian, GE, HSBC, ME, NAB,Suncorp, Toyota, Veda and Westpac in attendance. Matters discussed on the agendaincluded:

Questions were raised about Day 1 obligations 20 submissions received Key issues included defaults, usage for marketing purposes, EDR schemes, Code

Administrator Consideration of amendments to the CR Code Board to obtain draft by 4th June

Minutes ofARCAassociationmeeting dated21 May 2013

24 May 2013 AICM and ARCA host Privacy & Credit Compliance Solutions (PCCS) forum in Sydneyfocussing on credit reporting and discussing:

Changes to Part IIIA Impact and considerations of credit reporting changes for providers Legislative framework Status update regarding the CR Code

Attendees include: De'Longhi Australia Pty Ltd, Essilor Australia, Express Data, Halifax,Vogel Group, Hanson Construction Materials Pty Ltd, Manassen Foods Australia, MitsubishiElectric Australia Pty Ltd, National Credit Check Pty Ltd, News Limited, Nutricia AdvancedMedical Nutrician, NYK Line (Australia) Pty Ltd, Plumbers Supplies Co-Operative Limited,

PCCS slidedeck

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Reckitt & Colman Australia Ltd, Ricoh Australia Pty Ltd, Seven Network (OperationsLimited), SMEG Australia Pty Ltd, Southern Steel Group Pty Ltd, Standard CommunicationsPty Ltd, Talent International, Tillys Crawler Parts Pty Ltd

31 May 2013 Meeting between ARCA, CRN and OAIC – discussion of CR Code issues identified by OAIC31 May 2013 CIC meeting with Abacus, ABA, ACDBA, AFC, ARCA, Communications Alliance, Dun &

Bradstreet, ERAA, Experian, ICA, MFAA, NFSF and Veda in attendance. Matters discussedon the agenda:

Review of minutes Review of action items Credit repair agencies Update from OAIC CR Code feedback discussion Industry Code process Other business

Minutes of CICmeeting dated31 May 2013

5 June 2013 CR Code feedback session (Melbourne) attended by ARCA, CRN, ANZ, Dun & Bradstreet,Experian, GE, ME Bank, NAB and Veda. Discussion of amendments to the draft CreditReporting Code following public consultation and feedback from the OAIC & consumers.

6 June 2013 CR Code feedback session (Sydney) attended by ARCA, CRN, AMEX, Capital Finance, CBA,Dun & Bradstreet, Experian, Suncorp, Veda and Westpac. Discussion of amendments tothe draft Credit Reporting Code following public consultation and feedback from the OAIC& consumers.

18 June2013

ARCA meeting with Abacus, AMEX, ANZ, Capital Finance, Citi, D&B, Experian, GE, HSBC,ME, NAB, Toyota Finance, Veda and Westpac in attendance. Matters discussed on theagenda included:

Consideration to be given to Day 1 obligations Feedback and consultation on Draft CR Code V4.1 Meeting with OAIC to discuss Guidance & Explanatory notes, Code Administrator,

New default provisions, RHI and Transitional Compliance Strategy

Minutes ofARCAassociationmeeting dated18 June 2013

20 June2013

ARCA attends National Financial Services Federation (NFSF) to present on CR Code andimpact for micro-lending business owners from an operational viewpoint

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