The Australian Retail Credit Association kicked off its annual conference yesterday and over the next couple of days there will be plenty of focus on the association's core issue - credit reporting. New comprehensive credit reporting rules take effect next March.However, one thing delegates will not learn much about is the new Credit Reporting Code of Conduct, the operational guide to the new rules. The Privacy Commissioner has yet to register the code, which was drafted by ARCA, and many in the credit industry are concerned that the March deadline is looming.ARCA distributed a draft document to the industry in April, and, after reviewing submissions, it submitted a revised draft to the Office of the Australian Information Commissioner in July. Nothing more has been heard.ARCA and the OAIC both confirmed that the code has not been registered, but neither went into details.What makes the issue pressing for credit reporting agencies and credit providers is that the code forms part of the regulatory framework of the new system; it 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 draft that was issued in April was widely criticised for being inconsistent with the legislation, overly technical and inadequate as a practical guide.Industry representatives were more diplomatic in their responses to the revised draft submitted to the OAIC in July, but there were still some strong criticisms.The principal solicitor of the Consumer Credit Legal Centre, Katherine Lane, said that of eight key issues it raised in its submission, three were partially addressed and five not at all. Lane also accused ARCA of being misleading in its revision, noting that items were marked as re-drafted whether the re-drafting met the outcome requested or not.Lane said: "In one spot it states that the consumer movement agreed to a grace period of five days [for performance reports] when our submission clearly stated 14 days and was endorsed by all the relevant consumer organisations. Terribly misleading."The level of criticism directed at the first draft and, to a lesser extent, the revised draft probably explains the delay in getting the code registered. But that's all academic now; the industry wants to know what the rules are.