Submissions in response to a draft Credit Reporting Code of Conduct issued earlier this year have slammed the document, saying its writing is too complex, it is not a practical operational code, and, in some areas, it is not aligned with the legislation it is supposed to support.Submissions from ANZ, the Australian Finance Conference and a coalition of consumer groups (the joint consumer submission) have called for wholesale re-writing of what they see as a flawed document.The draft Code, which was prepared by the Australian Retail Credit Association, forms part of the regulatory framework for a move to comprehensive credit reporting in March next year, supporting amendments to the Privacy Act. The Code is not voluntary and will have regulatory force. Breaches will attract penalties of up to A$1.7 million.The Code covers reporting, disclosure and staff training rules, error correction and dispute resolution requirements, as well as auditing and compliance obligations The Australian Finance Conference made the most trenchant criticism of the draft. Its submission said: "The code was intended to be an operational code and align with the legislation. It should not look to re-open debate on policy positions. Nor should it be used as a de facto means of addressing perceived gaps [such a hardship processes]."The AFC said the whole structure of the document needed to be changed. "Compliance should be structured from the position of the category of regulated entity… We suggest some consideration be given to revising the current structure."ANZ said that, in some respects, the Code did not reflect the legislation as drafted. Its submission said: "One clause refers to a prohibition on credit providers disclosing personal information in relation to consumer credit to a credit reporting body if that personal information is not credit information."ANZ's view is that this is not a correct reading of the legislation. "The legislation does not cover the disclosure of personal information that is not credit information."It also argued that the Code's rule in relation to keeping records of credit reporting data was not consistent with the legislation.ANZ said aspects of the Code lacked clarity. The Code will require a credit provider to ensure that an individual from whom it collects personal information is aware of how that information will be held. ANZ said it was not clear what was required by way of explanation.The joint consumer submission was no less critical. It said: "An industry code should be seeking to set standards of best practice and deliver tangible outcomes for consumers. The fact that this is a mandatory code should not diminish those objectives. We are concerned that the Code does not deliver on those objectives as currently drafted."Another concern was that the Code is difficult to read and understand. "Clarity needs to be significantly improved," the submission said.The joint consumer submission said there were eight key issues that had not been addressed and another 10 that had been dealt with inadequately. The biggest concern is that there is no clarity about which entities can report repayment history