It is the job of many junior lawyers to deal with the day-to-day operations of the PPS Register: searching the register, interpreting search results, making registrations, amending registrations, discharging registrations, and communicating the information required or obtained to their clients.
The current complexity of searching the register and interpreting search results is a barrier to small business using the PPS Register.
Relevantly, this requires possession or control of the collateral or the filing of an appropriately drafted financing statement on the PPS Register.
We submit that negligible benefit would be provided to other stakeholders by deleting s 8(1)(f)(v) and that any benefit would be outweighed by the material impact on the ease of access to the product, the administrative burden and cost that would be placed on those who borrow to fund general insurance policies or by the clutter that would be added to the PPS Register by the making of potentially around 450,000 additional PPS registrations each year.
In our submission, it could be simpler to perform a search on the PPS Register and to interpret search results.