Click here to open our Industry Code Development Process Consultation document (PDF 1031kb).

Click here to visit the Credit Code Independent Review website.

As part of reforms to Australia’s privacy regime, the current Credit Reporting Code of Conduct is being updated.

To ensure data is accurate, up to date, complete and relevant, ARCA strongly supports updating the current single, mandatory Credit Reporting Code of Conduct. We believe that task is best undertaken by industry. ARCA is taking a lead role to facilitate industry and community feedback on the edited Code.

ARCA will be supporting a Code development process that meets current best practice standards:

• ASIC Regulatory Guide 183 - Approval of financial services sector codes of conduct (2007)
• Office of the Australian Information Commissioner, Privacy Code Development Guide (2001)
• Office of the Australian Information Commissioner, Privacy Code Development Guide (2001)
• ACMA, Developing Telecommunications Codes for Registration: A Guide (2003)

Data quality is essential to ensuring an effective and accessible credit reporting system. To ensure that data quality is at the heart of the credit reporting system, ARCA proposes that the amended Code has specifically built-in arrangements to facilitate an ongoing commitment to data quality.

ARCA proposes that data quality be addressed in a holistic fashion via a three pillar approach consisting of:

• a single data standard,
• the requirement of reciprocity, and
• an effective adequately resourced means of independent oversight.

Ensuring a consistent data standard will facilitate data quality across the credit reporting system. A single data standard will ensure transparency through the credit reporting system and will give a clear understanding of what data is in the system. ARCA fully supports a flexible approach that can accommodate different a standard between each industry sector – but also consistency within each sector.

Reciprocity is the foundation for ensuring accurate, up to date, complete and relevant credit reporting information. ARCA believes that credit reporting information must be shared on the principle that Credit Providers should contribute all of their chosen level of data (negative, full or partial comprehensive) to receive all data at the same level in return. Reciprocity is required to encourage users of credit reporting to provide their data, which in turn will ensure the most holistic picture of a consumer’s credit profile possible. This profile will ensure more responsible lending decisions are made by users of the credit reporting system. ARCA believes the most effective way of ensuring data is accurate, up to date, complete and relevant is to ensure reciprocity is a key feature of compliance with the credit reporting system, rather than a commercial or business decision taken on a case by case basis.

Finally, ARCA proposes the establishment of an independent committee to drive compliance with the Code. We propose the committee comprise representation from both industry and consumer advocates. While we would expect to finalise arrangements in consultation with industry and the regulator, ARCA proposes that this committee would support the work of the regulator, maintain industry focus on compliance with the Code, and to undertake compliance tasks associated with the Code.