The MFAA submission on behalf of its members does not support the recommendation to develop a monopoly model for these services. Its submission outlines the industry's concerns of suggested improved service levels under a proposed monopoly model which the MFAA believes would disadvantage its members as small business owners and have little impact on the major credit providers. The need for two alternative EDR providers better supports the different types of customers and businesses serviced by each scheme while offering members the choice of provider.
In the MFAA's view, the proposal is anti-competitive, lacks efficiency, equity, transparency, accountability and comparability of outcomes. Its submission deals with each of these review objectives.
The report's recommendation to establish a new superannuation ombudsman scheme to avoid consumer confusion between the current Superannuation Complaints Tribunal (SCT) and FOS undermines its argument to combine the CIO and FOS. This supports the MFAA recommendation to retain two scheme providers within the financial services and credit sectors.
The MFAA contends that a monopoly environment does not foster a better approach but the weight of evidence supports a negative impact on the proposed model in terms of member's pricing, innovation, competition and efficiency in dispute resolution outcomes. The MFAA suggests that responsiveness of the disputes process for both customers and financial service providers would not be effective in a 'one size fits all' approach recommended in the Report.
The MFAA submission addresses each of the objectives in the review's recommendations and it can be accessed here.