One-Stop Shop: Consumer Credit Issued at the Point of Sale

In Australia, most providers of consumer credit must possess an Australian Credit Licence (ACL). Licensees are subject to obligations, including "responsible lending" requirements. At present, providers of goods or services who offer credit to consumers at the "point of sale" are exempt from this licensing requirement. In 2019, the Commonwealth Government pledged to abolish this exemption. More recently, however, it has moved to repeal much of the responsible lending regime. This article outlines the unique features of point-of-sale credit. Drawing on focus groups conducted by the authors, it evaluates claims that point-of-sale credit can cause harm, particularly to vulnerable consumers. It concludes that even if the responsible lending regime is no longer to have general application, all providers of point-of-sale credit should be required to obtain an ACL. They should also be subject to specific rules, like other "high-cost", "high-risk" products such as payday loans and consumer leases.