The Australian Securities and Investments Commission's enforcement activity fell by more than half in the years between 2006/07 and 2008/09 and has remained at a low level ever since, according to a submission to a Senate committee inquiry into ASIC's performance.The Consumer Action Law Centre said there was a need for ASIC, along with other consumer protection bodies, to increase the amount of enforcement work it undertakes.For its submission to the Senate Standing Committee on Economics, CALC delved into the annual reports and other published information of two national and eight state and territory consumer protection regulators over the past six years. It said: "Regulators' enforcement performance has rarely been strong during the six years under review and in some cases it has got worse. For several regulators the amount of enforcement work undertaken has declined over the period examined."In ASIC's case, enforcement activity fell from around 275 actions in 2006/07 to around 120 in 2008/09 and has remained at that level ever since. Enforcement activity includes civil and criminal litigation, enforceable undertakings, bans, cancellations, suspensions and fines.The most marked downturn was in relation to criminal and civil proceedings.One area where ASIC's enforcement activity increased was in the number of enforceable undertakings.CALC said regulators should ensure that they are undertaking enforcement action in a strategic way designed to achieve stated outcomes. It said that ASIC "did not have an enforcement policy prior to February 2012."The submission also takes the regulators to task over their reporting. It said: "The way in which regulators report their performance is far short of the standard required to enable governments and the public to hold them accountable for their use of public funds."Regulators rarely report against all enforcement powers, types of wrongdoing or industries. Reporting is not timely or frequent enough. And reported information is not comparable between jurisdictions and often not fully comparable across time."Urgent attention is required to improve the transparency and accountability of consumer protection agencies."ASIC fares well in this department, however. CALC described it as a leader in terms of clarity, comprehensiveness and frequency.CALC said that before 2012 ASIC data was "not particularly helpful". "It was virtually impossible to ascertain what information related to each of its main regulatory functions. Statistics did not distinguish between ASIC's role in the regulation of the financial services industry and its roles in regulation of capital markets or administration of the company register."However, a policy change in that year has led to a significant improvement. CALC also said that since the beginning of 2012 ASIC has increased its willingness to comment publicly on issues - a necessary ingredient in effective enforcement policy. CALC said it detected an increasing unwillingness on the part of regulators to litigate because of the negative media and political commentary that followed a loss in the courts.It said: "It is not all about winning. Regulators have an important role in taking on cases to test the limits of the law. Few others are in a position to do this. "Taking on