Retail bankers are bracing themselves for the tabling next week of the National Consumer Credit Protection Bill, which will move consumer credit law from the states to commonwealth jurisdiction.Bankers applauded the decision of the states last year to hand over their consumer credit powers to the commonwealth, but over the past couple of months they have become increasingly concerned about the direction of the legislation and the approach of the Australian government to consultation on the issue.The government released a draft of the bill at the end of April. Submissions in response to the draft have criticised the approach being taken by the government for being too prescriptive, not giving large financial institutions enough flexibility to operate with responsible lending systems already in place and creating a complex and costly credit assessment process.Banks have argued in their submissions that the bill, as it stands in draft form, would make it more difficult to provide certain types of finance, such low doc and residential investment loans and  credit card limit increases.When the then Minister for Superannuation and Corporate Law Nick Sherry released the draft bill on April 27, it was clear that the government was intent on doing more than turning existing state law into a unified commonwealth law. The scope of consumer credit law was expanded to include margin lending and residential investment loans.The draft also set out principles of responsible lending. These principles cover new loans, refinancing, increases in credit limits and also situations when a licensee recommends that a consumer remain in an existing credit contract.Lenders will be required to assess whether a proposed loan is suitable for a client. They will have to gather specific information from the applicant and they will have to assess such things as whether a credit contract would impose "substantial hardship" on a borrower.These provisions came in for plenty of criticism in submissions.ANZ's submission argues that the bill does not reflect established lending practice, where credit assessment methods vary according to the product and the stage of the customer's relationship with the credit provider. The submission says: "The bill... places value only on verification of customer provided data. It does not appear to place any value on the data already held by credit providers on existing customers."It should be "a judgement based on the risk of the customer and the product."The Australian Bankers Association has criticised a provision that calls for a preliminary assessment or pre-application process when the customer first approaches the lender for credit.  This process has to be completed before the customer can make a formal application.The ABA submission says: "This is a convoluted process which consumers will not appreciate. As there is more paperwork delays will eventuate." Other submissions made similar comments about the requirement to issue a "credit guide" to customers. This measure has been likened to the requirement for financial planners and wealth managers to issue a statement of advice to their customers, a measure brought in with the Financial Services Reform Act that has been