Lead Generation Activity
24 June 2026
On 11 June 2026, the Law Council provided a submission in response to the Treasury’s Consultation Paper ‘Curbing lead generation activity’. The submission reflected input from the Consumer Law Committee and Superannuation Committee of the Law Council’s Legal Practice Section, and the Financial Services Committee of the Law Council’s Business Law Section.
The Consultation Paper sought feedback on options to curb high-pressure sales practices associated with cold calling and lead generation, particularly in relation to superannuation products. It is part of a wider suite of reforms responding to the collapses of Shield Master Fund (Shield) and First Guardian Master Funds (First Guardian).
The Law Council’s submission acknowledged Treasury's concerns about the risks of lead generation in relation to financial products and services. The submission highlighted the significant consequences for consumers affected by inappropriate practices, while noting that not all lead generation is inappropriate and that factual, balanced information can have consumer benefits. The submission canvassed several different options put forward in relation to lead generation activity, anti-hawking requirements, conflicted remuneration, advertising disclosure and ASIC's stop order powers.
A recurring theme of the submission was the need to assess the adequacy and enforcement of the existing regulatory framework before introducing additional or duplicative requirements, while recognising that targeted reform may be warranted in some areas. The submission recommended that Treasury produce a comprehensive roadmap of all the law reform proposals intended to address the circumstances in Shield and First Guardian, to support a holistic and coordinated response rather than one that is piecemeal and fragmented.
Last Updated on 25/06/2026