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Grounds/Reasons for Written Questions
Chapter 1.
Productivity Commission and the ABS rank Australians as having between Level 1
(low) and Level 5 (high) for Numeracy
and Literacy Skills.
A person assessed at Level 5 possess up to five times the skills within the
particular domain (eg Numeracy, Literacy, Prose etc) than a person assessed at
Level 1.
Level
3 or above is required "to
meet the complex demands of everyday life and work in the emerging
knowledge-based economy"
ASIC
2010 report notes "These
findings have implications for our regulatory regime, which relies upon
disclosure as a critical element of our consumer protection system. "
St. George and Westpac test Credit Cardholders with even Level 5 Numeracy
and Literacy Skills by
expecting all their Credit Cardholders to read/comprehend voluminous Conditions
of Use in a
tiny font.
Productivity
Commission's Staff Working Paper
"Links Between Literacy and Numeracy
Skills and Labour Market Outcomes" dated Aug
2010 noted:
For nearly half of the
population were assessed at either levels 1 (the lowest level) or 2, both of
which are below the minimum level deemed necessary to participate in a
knowledge-based economy (level 3).
For example,
level 3 is regarded by the survey developers as the ‘minimum required for
individuals to meet the complex demands of everyday life and work in the
emerging knowledge-based economy’ (ABS 2006, p. 5).
In 2006, the proportion of the
working-age population (15–64 years) who had
Language Literacy Numeracy (LLN) skills at levels 1 or 2, supposedly lower
than the minimum required, was 44 per cent for prose literacy and document
literacy, and 50 per cent for numeracy (figure F.1). The proportion at
level 3 was 39 per cent for prose literacy, 37 per cent for document
literacy and 33 per cent for numeracy.
Productivity
Commission Impacts of COAG Reforms: Research Report - April 2012
ABS report
Adult Literacy and Life Skills Survey, Summary Results, Australia, 2006
included:
* "On
the numeracy scale,
approx. 7.9 million (53%) Australians were assessed at Level 1 or 2, 4.7 million (31%) at Level 3 and 2.4 million (16%) at Level 4/5".
*
On the problem solving scale, approx. 10.6 million (70%) Australians were
assessed at Level 1 or 2, 3.7 million (25%) at Level 3 and 800,000 (5%) at
Level 4 (table 1)"
* ABS
- APPENDIX 1
- LEVELS OF SKILLS for
PROSE LITERACY, DOCUMENTS
SKILLS, NUMERACY and PROBLEM SOLVING
-
explains the criteria for ABS's rankings.
ASIC Report 224
"Access to financial advice in Australia" -
December 2010 includes:
51
These results, when considered together with Australian Bureau of
Statistics‘ research into Australians‘ general document literacy and
numeracy,15
in particular
their ability to meet the complex demands of a knowledge-based economy,
suggest that about one in two Australians do not have the skills required to
make informed choices in their interactions with the financial services
sector.16
There is also
an identifiable age link, with document proficiency tending to decrease with
age.
14 For
example the 2008 ANZ study of financial literacy found that ‗67% of
respondents said that they understood the principle of compound interest,
but only 28% were
rated with a good level‘ of comprehension when they solved the problem‘,
ANZ Banking Group Limited,
ANZ survey of adult financial literacy in Australia, (The Social Research Centre) ANZ Banking Group, Melbourne, 2008, p. 19.
15
As part of an
international study, the ABS measured skills in document literacy, prose
literacy, numeracy and problem solving and found that approximately 7
million (46%) of Australians (and 7.9 million (53%) of Australians aged 15
to 74) had proficiency less than the minimum required for individuals to
meet the complex demands of everyday life and work emerging in the
knowledge-based economy‘ for document literacy and numeracy respectively‘,
Australian Bureau of Statistics,
Adult literacy and life
skills survey results, cat. no. 4228.0, ABS, Canberra, 2006, p.
5.
16
These findings
have implications for our regulatory regime, which relies upon disclosure as
a critical element of our consumer protection system.
The Australian Govt & ASIC
National Financial Literacy Strategy
2014–17 included:
"The ABS research groups literacy and numeracy
into six skill levels (where below Level 1 is lowest and Level 5 is
highest), and problem solving in technology-rich environments (PSTRE) into
four skill levels (where Below Level 1 is lowest and Level 3 is highest).33
The Productivity Commission’s analysis of these results highlights that many
Australians have relatively low literacy and numeracy skills and this limits
the range and type of tasks that they can do in comparison with those with
relatively higher skills.34
Groups with relatively low literacy and numeracy skills include:
‘people
with low levels of education; older persons; people not working; and
immigrants with a non-English speaking background’. 35
Behavioural indicators
Research tells us that
Australians have differing attitudes to money and varying levels of
financial knowledge and proficiency.22 People may perform well on some
aspects of financial literacy, but poorly on others.23
The latest report on
Australians’ financial literacy, the 2011 ANZ Survey of Adult Financial
Literacy in Australia (ANZ Survey), is the fourth in a series of
national snapshots conducted by the ANZ Banking Group since 2003.24
Many people underestimate the
extent of their own knowledge gaps. So their behaviour, even in simple
day-to-day money management, may not be consistent with how confident they
are in their abilities. As discussed on page 8, individual financial
decision-making behaviour may also be influenced by personal or
environmental circumstances.
The 2011 ANZ Survey also highlighted a number
of areas of behavioural vulnerability, particularly in keeping track of
finances and planning ahead:
-
one third (36%) found dealing with money
stressful, even when things were going well
Results of the 2011 ANZ Survey confirm the complex and variable nature of
individual financial decision-making. A range of factors were found that may
help explain differences in financial literacy levels, such as financial
attitudes, age, financial knowledge and numeracy, household income, and
education and occupation.29
The Productivity Commission’s analysis of these results highlights that
many Australians have relatively low literacy and numeracy skills and this
limits the range and type of tasks that they can do in comparison with those
with relatively higher skills.34 Groups with relatively low
literacy and numeracy skills include: ‘people with low levels of education;
older persons; people not working; and immigrants with a non-English
speaking background’.35
Research shows that
Australian women typically have lower numeracy levels, find dealing with
money stressful or overwhelming and have more difficulty with
retirement-related investment decisions than men.63"
The above
extract of page 13 of the
National Financial Literacy Strategy
2014–17
notes that according to the ABS 21.5% of the Australian population do not
posses the Numeracy Skills to "shopping around
for the best deal on a credit card"
or
making timely credit card or
mortgage repayments.
"A necessary part of financial literacy is
knowing how to track your expenses and live within your means.
Data from
Roy Morgan Research in 2012 shows that, within the 16–24 age group, one in
10 carry forward more than $2,000 in credit card debt each month, suggesting
difficulties in managing money.49"
"Feedback from the 2013 Consultation also
identified the need for a mechanism to share relevant findings from existing
national surveys (for example, focusing on the savings and credit card
behaviour of Australians)."
These results, when considered together with Australian Bureau of
Statistics‘ research into Australians‘ general document literacy and
numeracy, 15
in particular their
ability to meet the complex demands of a knowledge-based economy, suggest
that about one in two Australians do not have the skills required to make
informed choices in their interactions with the financial services sector.16
There is also an identifiable age link, with document
proficiency tending to decrease with age.
The above published reports from the
Productivity Commission, ABS and ASIC is patent evidence that a
“community service
obligation”
has existed for at least 20 years for
the (small 'g') government to take stringent action because during that
post-deregulation era
Credit Card Issuers
have -
(a)
targeted Australians with low
Financial
Literacy Capacity
that are
Financially Uneducated And Vulnerable
to
Unconscionable Conduct through
Predatory Advertising
(b)
by promoting some
Credit Card Products
that charge
Usurious Interest Rates and
apply excessive
Late Payment Fees,
because the below
Chapter 8
evidences that the
12.58%
circa of
Credit Cardholders
that are identified by the
Reserve Bank in its
Submission
to the Senate Inquiry into Matters Relating to Credit Card Interest Rates -
Aug 2015 -
Submission 20,
as
Persistent Revolvers,
that
are contributing 80%
circa of
Interest and Penalty Fees Revenue
-
displayed in Figure 3 in Chapter 8 below.
Relying upon the
Productivity Commission and the
further ABS above rankings for the
domains/categories of
Numeracy and Literacy Skills, less than half of the top Level 5
Credit Cardholders (approx 5% of
Credit Cardholders) could
read and comprehend the follow three Conditions of Use booklets from St. George,
ANZ and Westpac:
St George's 62 pages
Conditions of Use - Credit Guide
"Effective 20 May 2014"
- 60 pages
are written in tiny 8.5 Helvetica font.
The word 'interest' appears in the
'Contents' twice and 77 more times throughout the 62 pages. The word 'fee'
or 'fees' appears 53 times.
Page 2 of the
Conditions of Use - Credit Guide
includes:
"We strongly recommends
that you read this booklet carefully....".
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ANZ's 'CONDITIONS
OF USE 20.06.2016 CONSUMER CREDIT CARDS'
booklet contains 97 pages in tiny Arial 9 font.
Page 6 notes:
'Introduction' "The credit card
contract governs the operation of the credit card account and your use of a
credit card. It is important that you read and understand the credit card
contract. The credit card contract is set out in your Letter of Offer and Parts
A and B of this booklet."
"The
following summary is designed to highlight some of the important information
about your credit card account and to help you identify where to find further
details within this booklet. The summary is not a substitute for the terms of
Parts A and B of this booklet, which
you should still read and understand."
Part A of the booklet has 51 pages. Part B has 22 pages.
Further in 'Introduction' is:
"Finally, you should also read the notice ‘Things
you should know about your proposed credit contract’,
which is included in this booklet following Parts A and B." '
'Things you should know about
your proposed credit contract’ is 7 pages. Hence, ANZ tells its
Credit Cardholders to read the entire 97 pages of its booklet.
Clause (4) 'Allowing
use by others' includes:
"(b) The account holder is responsible to ANZ for the operation
by an additional cardholder of the credit card account and any
other account linked to the credit card account. If an
additional cardholder does not comply with the credit card
contract, the account holder will be liable to ANZ. The account
holder should therefore ensure that each additional cardholder
receives a copy of the credit card contract and reads and
understands it."
The word "interest' appears 216 times in the booklet. The word 'fee' or
'fees' appears 104 times. |
Westpac has two
separate Credit Card booklets both "Effective as at 28 Oct 2016":
- "Combined
Conditions of Use and Credit Guide' for Credit Cards"
in Arial 11 font:
The word 'interest' appears in the 'Contents' once and 98 more times throughout
the 63 pages. The word 'fee' or 'fees' appears 90 times. The word
'Contract' appears 81 times.
Sub
clause (c) of clause 1.1 'Introduction' notes:
"These Conditions of Use do not, on
their own, contain all the terms applying to your Credit Card, so it
is important that you read all of the documents comprising the
Credit Card Contract carefully and retain them for future
reference."
Clause 17. 'Do I have any other rights and obligations?':
"Yes. The law will give you other
rights and obligations. You should also READ YOUR CONTRACT
carefully."
- "Ignite
by Westpac - Consumer Credit Card Conditions of Use" in
HelveticaNeue-Light 9 font.
The
word 'interest' appears in the 'Contents' once and 92 more times throughout
the 43 pages. The word 'fee' or 'fees' appears in the
'Contents' once and 74 more times throughout the 43 pages. The below statement appears on the front cover of "Ignite
by Westpac - Consumer Credit Card Conditions of Use":
"This User
Guide forms part of your Credit Card Contract, along with the information
set out on the reverse of your welcome letter which advises you of your credit
limit and other prescribed information we are required to give you by law."
Clause 17 is "Do I have any other rights and obligations? Yes.
The law will give you other rights and obligations.
You should also READ YOUR
CONTRACT carefully." |
CBA's Credit
Cards 'Conditions
of Use' booklet in Arial 10 font is only 21 pages.
The word 'interest' appears 44 times. The word 'fee' or 'fees' appears 20
times.
Clause 1.
of the booklet titled 'Your contract with us" notes:
"Please read both these Conditions of Use and the Schedule of Credit
Card Particulars in your letter of offer, which together make up
your contract and include the information we must give you."
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Refer:
Chapter
2.
Summary Page re Written Questions and the Grounds/Reasons
Grounds/Reasons
(one document with 21 Chapters)
Grounds/Reasons
(21 separate Chapters)
Written Questions
(one document with Written Questions)
Written Questions
(Individual Written Questions)
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