Disclosure and pawnbroking
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| Q.5 Do you agree that the proposal allowing compliance with the requirements of section 59 of the SDPA to meet the CCCFA disclosure requirements of section 17, and exempting pawnbroking from the continuing disclosure and prepayment requirements of the CCCFA, would reduce problems associated with the clashes between the SDPA and CCCFA for pawnbroking credit transactions? What advantages or disadvantages do you see the above proposal provides to consumers and traders? Are there other options to address the issue? |
Two substantial submissions were made on pawnbroking, with both suggesting the proposal to exempt pawnbroking from the continuing disclosure and prepayment requirements of the CCCFA, would reduce problems but does not go sufficiently far enough and does not address concerns about the treatment of interest, fees and charges and the consumer's right to cancel.
Both submissions proposed that pawnbroking be fully excluded from the provisions of the CCCFA. Both submissions suggested that if this was not possible, then pawnbroking should only be subject to the CCCFA's oppression provisions.

