Dr Jennie Gray WLSWA

What are your views on the proposed principles for developing the industry funding model?

Supportive of the proposed principles and suggest minor also that,

1. The model is flexible to ensure adaption and response to changing needs (eg, to natural disasters)
2. The model also contributes to improved promotion of financial counselling sector
3. The emphasis on ‘additional’ funding is maintained

What are your views on the proposed quantum for each year of the first three years of the model?

Whilst it is good that the industry funding model will generate resources for at least an additional 100 financial counsellors, if not more, the level of contributions appear modest alongside the profits financial services generate. Financial counsellors do a lot of the work, especially remedying, of financial services and their worth is not reflected in the relatively insignificant proportion proposed.

Are there any evidence-based adjustments that could be made to the suggested contributions methodology? What are they and how could they be incorporated into the methodology?

The shortfall between unmet need and unmet demand.

What is your view on the different methods for within subsector splits, for your subsector?

Subsector splits need to reflect the relative incidence of financial adversity across industry

What is your view on the proposed initial three-year commitment? Is this an appropriate length to ensure flexibility and stability of funding?

Three years strikes a balance between flexibility and certainty.

Another alternative is concurrent funding streams, 1-2 years and four years. This would allow different services to be delivered and might encourage some piloting of innovations in the provision of financial counselling, including organisations outside established providers.

When would an appropriate time be to review the functioning of the model?

Annual reviews, with built in opportunities to ‘check in’ as needed

Are peak organisations an appropriate mechanism to obtain a formal commitment from subsectors as part of the initial set up of the model? Are there alternative methods to secure commitments that could be undertaken in a timely manner?

Peak bodies, especially in each state jurisdiction, have good oversight and intel and need to be integral to the establishment of the model overall.

Which board composition option do you prefer and why? Are there other options?

Composition is critical. Option 2 is preferrable.

Need to ensure Peak bodies that have a high level view of the impacts of financial hardship and poverty, such as ACOSS, are included.

Governance structure must have mechanisms for lived experiences input

The involvement of corporate representatives has merit but will need careful management of potential conflicts and alignment with purpose.

An independent Chair is good, and appointment of this person needs to be widely supported and trusted.

The unique insights and experiences of the respective states need to be captured in the Board composition too.

What are your views on the proposed questions the evaluation could test?

Does industry’s enhanced awareness of the financial hardships that produce the need for financial counsellors need to be included in evaluation too?

Also an understanding of any residual shortfall in service provision (if any), and where this unmet need is ongoing and/or emerging

Improved coordination will be essential to measure and understand

Are there any other comments you would like to add?

Most women’s legal services around Australia have a financial counselling service embedded into our model of integrated assistance, thanks to funding via Financial Counselling Foundation

An in-house financial counsellor is of significant value to WLS’ given the high incidence of women who experience economic abuse as part of family violence.

The impact of debt, arrears, fines, and diminished material support is significant for these women, and often their children. Women cannot rebuild their lives and protect their children without access to safe and secure financial advice and support.

The FCF grants conclude 30 June 2023 and we would like to propose allocating a proportion of industry funding to ensure that these vital financial counselling service can continue to support women whose need has already been demonstrated through current service provision.

(Also understand that an opportunity to more fully develop this proposal will be available once the method to distribute funds has been established).