This article provides suggestions for you as to recommendations made under the “Whittaker Review” of the PPSA, and which are most relevant to you. Discussion topics for your views will also be open on CreditNetwork and AICM on LinkedIn for you to contribute your comments. Please contact Nick Pilavidis or I if you wish to discuss further approaches to government as well as other industry group representations, as we want to know what your and their issues are.
Why was there a review?
It was a requirement of the PPSA1 that a government review had to be completed by 30 January 2015.
Who was involved?
Bruce Whittaker2 was appointed by the government in April 2014 to conduct the review (which I will call “the Whittaker Review”).
On behalf of the AICM, I reviewed the material, with input from various members, and provided suitable submissions and responses to the Whittaker Review. Almost 160 separate submissions and response documents, by some 40 organisations were reviewed by me in this process.
Six(6) submissions and response documents were also provided by me (on behalf of the AICM) during the Whittaker Review.
What did the Whittaker Review say that is relevant to me, and what should I do?
Its recommendations (540 page report) were released in March 2015. The table on the following 2 pages contains some of these as likely
most relevant to you, with my initial comments as to what you should consider. It is now for government to consider this full report and decide what it wants to do, subject to any other representations.
You should consider now whether your business, industry body, or your stakeholders, should make representations to the government on any of the recommendations.
You should also plan when and what compliance changes you will make, or are likely to have to make.
How soon should I do something, and what should I do? Key Points.
There is currently no stated time frame for the recommendations to be dealt with. It is suspected however that many, especially as to the register’s functionality, may occur as early as within the next 3 - 6 months.
- From my experience, many businesses left it until just before or after the start of the PPSA register before dealing with issues. This cost them a lot of money e.g many lost transitional fee exemptions, due to not updating their T+C’s before 30 January 2012.
- Obtain advice immediately as to how to prepare for and deal with the recommendations (whether enacted in part or in whole) to benefit your businesses, and reduce your compliance time, costs and paperwork.
- The Whittaker Review has recommended that another review occur in 5 years’ time.
- The introduction of the PPSA regime into foreign countries is being pushed by various Governments and others. You should consider if your business, customers or suppliers operate in countries which have, or are considering, enacting PPS laws and registers similar to the PPSA (including the South Pacific and UK) and how compliance can be effected so as to deal with this.