The AADA supports efforts to bolster responsible lending practices, but believes that this can be done in a manner that does not duplicate process or drive up costs for consumers.

The AADA understands ASIC’s concerns regarding Add-on Insurance products but believes that the Government should impose a short deferral period no longer than two days and include some provision for the consumer to waive the deferral period.

The deferral period should commence when the consumer communication is received and cease at the earliest of the delivery of the vehicle or the end of the deferral duration.