FCVic has made a submission to the Victorian Law Reform Commission’s (VLRC) review of legal privilege and integrated legal assistance services. Drawing on the experiences of financial counsellors working within community legal centres and integrated settings across Victoria, the submission argues that integration doesn’t exist as a simple binary between “loosely” and “closely” integrated services, but operates along a continuum shaped by client cohort, organisational structure and area of practice. It cautions that an overly prescriptive legislative framework risks creating uncertainty and could discourage effective collaboration.

The submission draws a functional comparison between the information-gathering role financial counsellors play in integrated legal settings and that of paralegals and legal support staff, arguing this warrants similar privilege protections. It also highlights the benefits of integrated practice in reducing re-traumatisation for clients, particularly those experiencing family violence, by allowing them to tell their story once. FCVic’s six recommendations call for a reform approach that recognises the diversity of integrated practice models, supports collaboration between lawyers and financial counsellors, provides safeguards for sensitive practice areas, and preserves compliance with mandatory reporting obligations.

FCVic, together with our state and territory financial counselling peak partners, made a joint submission to the National Insurance Brokers Association’s (NIBA) consultation on the draft 2027 Insurance Brokers Code of Practice. Drawing on financial counsellors’ direct experience assisting clients affected by poor broker practices, insurance disputes, claims failures, underinsurance and vulnerability, the submission finds that while the draft Code is clearer and more accessible, it falls short of requiring compliance with the professional behaviour it describes.

The submission highlights recommendations that remain unaddressed, including clear broker due diligence obligations, written Statements of Advice, standardised disclosure templates for remuneration and conflicts of interest, and defined timeframes for claims handling. It argues that genuine self-regulatory credibility depends on enforceable, measurable standards rather than clarity alone, and offers to participate in further consultation workshops.

Co-signed by:

• Financial Counselling Queensland (FCQ)
• South Australian Financial Counsellors Association incorporating Northern Territory (SAFCA)
• Financial Counsellors Australian Capital Territory (FC-ACT)
• Financial Counselling Western Australia (FCWA)

FCVic made a submission to the Review of the Essential Services Commission Act 2001, arguing that the Act should be modernised to embed the consumer-focused approach the Essential Services Commission (ESC) has already developed in practice. Drawing on financial counsellors’ frontline experience, the submission calls for fair consumer outcomes, accessibility and the needs of people experiencing vulnerability and financial hardship to be recognised as core, primary considerations under the Act, alongside stronger requirements for accessible and meaningful consumer engagement in regulatory processes.

The submission also recommends expanding the ESC’s remit to cover toll road operators and major road-user charging schemes, given the serious consequences toll debt can have for people experiencing hardship, and to support consistent implementation of hardship frameworks across local government. It further calls for a broader range of enforcement tools to drive genuine accountability and behavioural change, particularly for government-owned entities and monopoly service providers, with any expansion of the ESC’s functions matched by appropriate funding. The submission was supported by the Infringements Working Group, Mortgage Stress Victoria and Westjustice.

FCVic recently lodged a submission on the future of Financial Counselling Australia’s Representative Council, following consultation with Victorian members, agency managers and sector leaders. The discussion has been overwhelmingly positive, constructive and collaborative, reflecting a shared commitment to ensuring the sector is represented effectively at a national level. Our submission supports governance arrangements that are transparent, accountable and informed by frontline experience, recognising the important role that both practising financial counsellors and peak bodies play in shaping the future direction of the profession.

FCVic has made a submission to the Insurance Council of Australia’s consultation on the draft General Insurance Code of Practice. The submission draws directly on the experience of Victorian financial counsellors supporting people through insurance claims after major disaster events, including the January 2026 Victorian fires and the October 2022 floods, as well as those supporting victim-survivors of family violence and households in severe financial hardship. We warmly thank the members who shared their casework insights and feedback through the FCVic Disaster Recovery Network — their generosity has allowed us to coordinate a truly member-led submission, and the twenty recommendations put forward are grounded in their frontline expertise.

While FCVic supports the objective of modernising industry standards, the submission raises serious concerns that the draft Code weakens existing consumer protections in several places and does not adequately address the recommendations of the Independent Review or the Parliamentary Inquiry into insurers’ responses to the 2022 major floods claims. Key recommendations include replacing discretionary language with mandatory obligations, requiring insurers to use a customer’s nominated method of communication, mandating acceptance of a standard authority form, extending protections to eligible small businesses, inserting a dedicated section on temporary accommodation entitlements, and ensuring expert reports are provided to consumers without delay or unnecessary redaction. FCVic supports the recommendations made in the joint consumer submission led by Financial Rights Legal Centre, and the submission by Financial Counselling Australia on vulnerability.

This submission should be read in conjunction with our earlier work on insurance and natural disasters:

• Unsettled: Climate Risk and Cash Settlements in Home Insurance
• Submission to the Independent Review of the 2020 General Insurance Code of Practice
• Submission to the House Standing Committee on Economics Inquiry into Insurers’ Responses to 2022 Major Floods Claims
• Submission to AFCA’s Joint Consultation on General Insurance Approaches
• Submission to AFCA’s Consultation on Approach to General Insurance Claims Handling
• Submission to the Insurance Brokers Code of Practice Review
• Submission to Treasury’s Consultation on Standard Definitions and Standard Cover for Insurance