Submission - Joint response to the Review of the Electronic Funds Transfer Code of Conduct (2008)

Proposal D1

D1Q1 Do you agree with this proposal? Please give reasons.

We propose to amend the EFT Code to:

(a) include a definition of ‘complaint’ using the definition in Australian Standard ISO 10 002 2006 Complaints Satisfaction—Guidelines for complaints handling in organisations; and

(b) require subscribers to establish internal dispute resolution procedures that comply with the new Standard.

D1Q1 Do you agree with this proposal? Please give reasons.

ASIC has proposed a requirement that Code members implement internal dispute resolution systems complying with Australian Standard ISO 10 002 2006 Complaints Satisfaction – Guidelines for complaints handling in organisations.

Consumer stakeholders continue to experience problems and frustration with internal dispute resolution in relation to EFT Code issues. The implementation of further guidelines is welcome, but is unlikely to lead to significant improvement without greater allocation of resources to monitoring and enforcement.

Although consumer stakeholders support this proposal, it is recommended that efforts focus on monitoring and enforcement (discussed below in Proposal G4 at page 19).





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