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5 October 2019

Ms. Adele Ferguson

PO BOX 4,
Collins Street West VIC 8007

Dear Ms. Ferguson

The Writer herewith provides a welter of evidence for a Second Wave of the Royal Commission into Financial Services:
*        one week of hearings from
Persistent Revolvers and Credit Card Distress Authorities; and

*        one week of cross examination of the Council of Financial Regulators, in particular its Chair (explained in Section 5 below)

Persistent Revolvers establishes that 12.58% circa of Credit Cardholders contribute a whopping 80% circa of all Interest And Penalty Fees Revenue generated from Credit Card Products

Labyrinth of Concealed Spiders exposes 'nine examples' of Unconscionable Conduct from Predatory Advertising of some Credit Cards

Credit Card Products evidences that the most widely used retail credit borrowing instrument in Australia is the most differentiated product (in both 'variety of types' and 'quantum of providers') in the entire Western World - by a country mile

If the 2018 Royal Commission into Financial Services had kicked-off by investigating Unconscionable Conduct by many Credit Card Issuers that manifested over the last 20 years, Commissioner Hayne could have expended all of 2018 cleaning up only one banking product, albeit the most prolifically used, such is the breadth and depth of Unconscionable Conduct ostensibly targeted at Financially Uneducated And Vulnerable Australians  Credit Cardholders  With Low Financial Literacy Capacity

Unconscionable Credit Card Interest Charging focuses on a significant change in interest charging for Credit Cards that a Red Faced ABA, under a parachuted in, Anna Bligh, has regulated on ALL Credit Card Issuers in Aust. to implement no latter than 1 July 2019 under the ABA's 'Banking Code of Practice'. These regulated changes followed years of deceit perpetrated voracity fostered under Ms. Bligh's two predecessors, David Bell and then Steven Münchenberg  

Australia's Principal Regulator of the Payments System should have regulated the changes in the ABA's 'Banking Code of Practice', pertinent to Credit Cards, over 25 years ago when the Bank Interest Rate Margin between the Overnight Cash Rate and the average Purchase interest rate exceeded 16% -  back in June 1992.  In not doing so, the RBA breached its Statutory Duty to "best contribute to.......... the economic prosperity and welfare of ALL the people of Australia" and the Payments Systems Board abrogated its responsibility to always Act in the Public Interest

If the SMH shares the Writer's belief that Australia's Principal Regulator of the Payments System failed in its Statutory Duty to inter alia re-impose a maximum interest rate on Credit Cards when the spread between to Overnight Cash Rate and the maximum interest rate for Purchases increased from less than 1% (April 1985) to 28% (March 2019) (for a Cash Advance) to the Extreme Financial And Emotional Distress of Persistent Revolvers, then the SMH should read inter alia the Writer's 3rd letter to Dr. Peter Brandson, Bank Reform Now dated 2 Aug 2019 (that seeks a second wave of the Royal Commission - a mere two weeks of hearings and cross examination) which inter alia provides -

*        Thirty Two Written Questions - most directed at the Governor of the Reserve Bank; and

*        extensive Supporting Documented Evidence to justify each of the Thirty Two Written Questions

 

1.       Pertinent events since mid-2010 by the Writer re Credit Card Products

2.       Earlier this year, the Writer provided all necessary evidence to Bank Reform Now for it to lobby for a second wave of the Royal Commission focusing on a breach of Statutory Duty by the Principal Regulator of the Payments System

3.       In April 1985 the RBA removed an 18% interest rate cap on Credit Cards when the Overnight Cash Rate was 17.2%. 
In the past "... when de-regulation resulted in adverse consequences, re-regulation ensued..." But not this time
.

4.       400,000 circa Credit Cardholders with Poor Numeracy and Literacy Capacity, often through no fault of their own, have paid a frightful price because of Unconscionable Credit Card interest rates, Predatory Marketing and Numeracy And Literacy Targeting 

 

5.       A brief second wave of the Royal Commission to right the wrongs within the most differentiated Product in the entire Western World, because -

            *        12.58% of all Credit Cardholders, invariable with low Financial Literacy Capacity, have paid 80% circa of all Interest and Penalty Fees Revenue; and

            *        five former Prime Minister's have attested that Australia is an egalitarian country

Yours sincerely

Philip Johnston - the Writer

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Declaration that the Writer is not conflicted

Some references & Documents Relied Upon