FCVic has made a submission to the Victorian Legal Services Board and Commissioner’s (VLSB+C) Consumer Strategy consultation. Drawing on direct feedback from financial counsellors about their clients’ experiences with fee-paying legal services, the submission paints a consistent picture: people in financial hardship often can’t get timely, affordable, and appropriate legal help. When they do, poor communication, unclear costs, and hard-to-understand advice can deepen their disadvantage, and many are too exhausted, fearful, or unsure to complain.

FCVic calls for a Consumer Strategy that recognises empowerment means more than giving people information. The submission urges clearer expectations for legal services on scope, fees, and regular updates, a complaints process designed for people who aren’t confident or legally literate, and stronger regulatory attention to family violence and economic abuse, opaque fees, and debt recovery practices that ignore hardship. It also highlights the value of integrated services where lawyers work alongside financial counsellors, and the need for a regulator prepared to act on patterns of harm even when formal complaint numbers are low.

FCVic has made a submission to the Essential Services Commission’s (ESC) consultation on its Targeted Consumer Reforms and Regulatory Efficiency Draft Decision Paper, which proposes amendments to the Energy Retail Code of Practice. Informed by feedback from the FCVic Essential Services Network, the submission supports most of the proposed reforms as sensible changes that reduce regulatory burden without materially reducing consumer protections. However, FCVic is disappointed that more substantive reforms on family violence protections and closed account debt have been deferred, and calls on the ESC to publish a clear timeframe for reconsidering them.

The submission strongly supports clarifying that retailers must comply with their own published complaints handling and dispute resolution procedures. It argues that any move towards principles-based obligations must come with minimum expectations, monitoring, and accountability. FCVic also raises concerns about removing start and end meter reads from bills for customers with interval meters, and about reducing non-digital payment options for older Victorians and people experiencing digital exclusion. The submission is supported by WEstjustice.

FCVic has made a submission to the Department of Home Affairs’ consultation on reforming Australia’s settlement grants programs. Drawing on the experience of financial counsellors who regularly support people from migrant and humanitarian backgrounds, the submission welcomes the Government’s focus on economic participation, economic security, and access to services, and argues that financial wellbeing and stability should be recognised as foundations of successful settlement.

The submission calls for financial capability and financial literacy education to be delivered by appropriately qualified workers, consistent with current Department of Social Services grant requirements, and for clear referral pathways to financial counsellors for people experiencing hardship or complex financial issues. It also stresses that settlement services should provide independent information that helps people compare options and make their own decisions, rather than directing them towards particular products or providers. Finally, it urges the Government to ensure its own systems, including debt administration, are accessible, trauma-informed, and responsive to vulnerability and family violence, and attaches an FCVic briefing paper on Home Affairs debts, family violence, and migration outcomes.

FCVic has made a submission to the Tax Ombudsman’s review of the Australian Taxation Office’s (ATO) administration of Director Penalty Notices (DPNs). The submission recognises that DPNs are an important compliance tool, but notes that their consequences can be severe and, in some cases, irreversible. Drawing on the experiences of generalist and specialist small business financial counsellors, it argues that the ATO must distinguish deliberate non-compliance from circumstances involving financial distress, vulnerability, coercion, or a lack of information when a business is first set up. FCVic thanks the FCVic Small Business Network, especially the specialist small business financial counsellors at Each, for the insights and expertise that informed this submission. We also acknowledge and support the feedback provided to this review by our colleagues at Financial Counselling Australia.

The submission makes 27 recommendations covering communication, early intervention, vulnerability, and ATO capability. These include linking Director IDs to individual myGov or ATO accounts, clearer and trauma-informed DPN communications, an early-intervention framework that responds to signs of financial distress, and a specialist pathway for coerced and disputed directorships, with recovery action paused while concerns are assessed. FCVic also calls on the Australian Government to implement key recommendations from the Parliamentary Joint Committee’s financial abuse inquiry, and for the ATO to formally recognise financial counsellors as trusted intermediaries.

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.