FCVic’s submission to the Australian Financial Complaints Authority (AFCA) consultation on the Approach to family violence and Approach to financial elder abuse (the Approaches) highlights the critical need for trauma-informed, safety-first practices when addressing financial complaints involving these complex issues. Drawing on the expertise of Victorian financial counsellors, the submission advocates for stronger language, clearer evidentiary standards, and improved procedural safeguards to prevent further harm to victim-survivors.

The submission makes a series of detailed recommendations aimed at improving AFCA’s complaint handling processes, including adopting more inclusive and respectful terminology, recognising the evidentiary challenges faced by victim-survivors, and strengthening safeguards around identity verification, insurance cancellations, and power of attorney misuse. It also calls for a review of industry standards and case examples to ensure AFCA’s Approaches reflect current best practice and lived realities.