Deferred Management Fee Nonsense

The Jacinta Allan Government new definition of the 'Deferred Management Fee' as a fee for 'services' has ZERO functionality. 

This change is from the new proposed Victorian Retirement Villages Act.

ZERO functionality comes from the fact that village residents already pay 100% of the cost of 100% of the management services that Victorian retirement village operators claim and charge for as necessary to successfully operate the village.

Under Australian consumer law an operator cannot charge for ‘services’ where 1. there is no intent to supply or 2. no supply has in fact been made.

Competition & Consumer Act 2010
Chapter 3. 3-1 Unfair practices. Division 1. 36 - Wrongly Accepting Payment.

36-1 A person must not, in trade or commerce, accept payment or other consideration for goods or services if, at the time of the acceptance, the person intends not to supply the goods or services.

36-4 A person who, in trade or commerce, accepts payment or other consideration for goods or services must supply all the goods or services:

WHAT ARE THE NEW FEES?

HOW CAN THEY BE SUBSTANTIATED?