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ARTICLE · 10 JUNE 2026

HSF Kramer Submission – Treasury Consultation On Curbing Lead Generation Activity

Herbert Smith Freehills Kramer LLP
Herbert Smith Freehills Kramer LLP
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Herbert Smith Freehills Kramer LLP

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On 7 April 2026, Treasury released a consultation paper seeking feedback on policy options to curb lead generation activity linked to financial products, with a view to better protecting consumers...

AustraliaFinance and Banking
Andrew Bradley
Andrew Bradley
Tamanna Islam
Tamanna Islam
Michael Vrisakis
Michael Vrisakis
Maged Girgis
Maged Girgis
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On 7 April 2026, Treasury released a consultation paper seeking feedback on policy options to curb lead generation activity linked to financial products, with a view to better protecting consumers from high pressure sales and cold calling. The consultation is in response to the collapse of the Shield and First Guardian Master Funds.

Our team has made a formal submission on this consultation.

We agree with and strongly support the need to properly protect retail clients in the Australian financial system from harmful lead generation practices, such as practices of the kind alleged in relation to the Shield and First Guardian collapses. However, we consider that certain of the reform proposals canvassed in the Consultation Paper would have unintended effects beyond the regulation of harmful lead generation practices, and risk unduly restricting legitimate marketing, financial advice and consumer engagement activities.

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