It follows that measures would need to be in place to ensure the business maintains its organisational competence at all times including having measures in place for: The review of organisational competence on a regular basis or whenever responsible managers change; The maintenance and updating of qualifications and experience of responsible managers and ensuring that responsible managers undertake a certain level of continuing professional development - perhaps 20 hours per year for consistency with the obligations imposed upon licensees under the National Credit Act; and The keeping of records showing the business has reviewed its organisational competence and the steps taken to maintain such competence. We may be prepared to support a positive competence obligation. Training of employees ACDBA members accept their responsibility to ensure their employees are adequately trained and competent to engage in the collection activities undertaken. Again, staff competence is crucial to commercial success. Training requirements, however, will vary across businesses depending on business model and the scope of the duties required. Currently, training obligations for the Collectors sector across State and Territory jurisdictions vary from the Code of Conduct approach taken in Queensland, which places a positive onus on businesses to ensure a commercial agent has a reasonable knowledge and understanding of PAMDA and the Code to no specific requirements, as is currently the situation in a number of jurisdictions such as Victoria. In NSW collectors are required to complete modules from the Financial Services (Mercantile Agents) Certificate III qualification of the national training framework. members mostly regard this specific requirement to be excessive, counter-productive and a significant impediment to the ability of the Collections sector to employ staff in that state. ACDBA’s perspective is it is appropriate any training regulations for the Collections sector should always be relevant and cost effective and further that any prescribed training ought to be accessible, especially given the issue of staff turnover. As an example, ACDBA members indicate new staff turnover in NSW can range from a minimum of 35% to in excess of 60% of any intake. Accordingly, it is appropriate our members determine what is appropriate for initial and ongoing training of employees to ensure organisational competence. This is consistent with the approach ASIC has taken for the majority of licensees under the NCCP regime. ASIC views them as being in the best position to determine training requirements. In addition, our Association is well placed to support the industry in the continued development of an agreed industry standard for induction and refresher courses.
It follows that measures would need to be in place to ensure the business maintains its organisational competence at all times including having measures in place for: The review of organisational competence on a regular basis or whenever responsible managers change; The maintenance and updating of qualifications and experience of responsible managers and ensuring that responsible managers undertake a certain level of continuing professional development - perhaps 20 hours per year for consistency with the obligations imposed upon licensees under the National Credit Act; and The keeping of records showing the business has reviewed its organisational competence and the steps taken to maintain such competence. We may be prepared to support a positive competence obligation. Training of employees ACDBA members accept their responsibility to ensure their employees are adequately trained and competent to engage in the collection activities undertaken. Again, staff competence is crucial to commercial success. Training requirements, however, will vary across businesses depending on business model and the scope of the duties required. Currently, training obligations for the Collectors sector across State and Territory jurisdictions vary from the Code of Conduct approach taken in Queensland, which places a positive onus on businesses to ensure a commercial agent has a reasonable knowledge and understanding of PAMDA and the Code to no specific requirements, as is currently the situation in a number of jurisdictions such as Victoria. In NSW collectors are required to complete modules from the Financial Services (Mercantile Agents) Certificate III qualification of the national training framework. members mostly regard this specific requirement to be excessive, counter-productive and a significant impediment to the ability of the Collections sector to employ staff in that state. ACDBA’s perspective is it is appropriate any training regulations for the Collections sector should always be relevant and cost effective and further that any prescribed training ought to be accessible, especially given the issue of staff turnover. As an example, ACDBA members indicate new staff turnover in NSW can range from a minimum of 35% to in excess of 60% of any intake. Accordingly, it is appropriate our members determine what is appropriate for initial and ongoing training of employees to ensure organisational competence. This is consistent with the approach ASIC has taken for the majority of licensees under the NCCP regime. ASIC views them as being in the best position to determine training requirements. In addition, our Association is well placed to support the industry in the continued development of an agreed industry standard for induction and refresher courses.