Ms Derville Rowland:

From a consumer protection point of view, when we look at the regulation and the framework of regulation for the loan owners about whom the Senator is talking, they do not have the same regulatory framework as a bank. There are no capital requirements in the regulatory framework. That is not part of it. We have developed and published regulatory requirements they must meet before they can get a full authorisation from the Central Bank. These include fitness and probity of the individuals leading the organisations. Very importantly from our point of view, they must demonstrate mind of management in this jurisdiction. They must demonstrate a structure that we are capable of supervising. It cannot be so complex that one cannot follow where decision making is happening and they must demonstrate the resources, governance and structures to be able to discharge the high standard of regulatory requirements we would expect of them. As such, they must show us that they have a competent and well-developed compliance function that is embedded and have risk management frameworks in place. There is a whole flotilla of regulatory frameworks they must demonstrate before they will get the authorisation. They must show us that they can hit the ground running for the interaction and standards we expect when dealing with their customers. We are conscious that many of these customers are in a vulnerable position and it is very important that the loan owners have the proper standards. This is the close look at the regulatory framework in respect of the standards they must meet.