One day after the Royal Commission into Misconduct in the Banking, Superannuation and Finance Sector announced it was ready to accept submissions, the Consumer Action Law Centre has published part one of its submission. The Centre said its submission "draws on the experience of the Centre assisting Victorians through legal advice and representation, and financial counselling."The conduct and practices that have, in its opinion, fallen below community expectations include: irresponsible lending, particularly in relation to credit cards, car finance and home loans - for instance, citing its own case work, Consumer Action noted that "it is common for an intermediary (usually the car dealer) to 'broker' a loan at the car yard as part of the sale process. … without borrowers having any contact with the lender"; unlawful sales practices in relation to insurance, property spruiking and timeshare - for instance, low-value, unsuitable add-on insurance being sold in car dealerships; the design of credit cards - typically, where credit card lenders 'bundle' complex pricing structures in their marketing and product information, which makes the overall costs difficult for the average consumer to understand;     the marketing of credit - a prohibition on unsolicited credit card limit increase offers can be easily circumvented by lenders using the 'consent' loophole, provided the consumer has 'opted in', and the prohibition does not apply to overdrafts, personal loans and other types of credit; excessive bank fees - for instance, penalty fees (some as high as A$40) that bear no resemblance to the direct costs incurred by the bank from the event which triggers the fee, and which have increased sharply since 2016, when the High Court upheld the lawfulness of these fees; and poor customer service and complaints handling.The submission makes the point that automated use of automated systems to process and approve applications for unsecured credit "is particularly problematic".It cited the Code Compliance Monitoring Committee Annual Compliance Statement program: "… banks have not demonstrated, to the CCMC's satisfaction, that the use of an automated system or statistical credit scoring model alone is sufficient to comply with the [Code of Banking Practice] obligations…"The Consumer Action Law Centre said it would publish part two of its submission in the coming weeks, looking at some of the reasons for misconduct in the finance sector and the effectiveness of redress mechanisms. The major banks are expected to file their submissions early next week.