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

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Proposal F3

• F3Q1 Should the EFT Code prohibit the use of hyperlinks to deliver disclosure required under the EFT Code?

 

F3Q1 Should the EFT Code prohibit the use of hyperlinks to deliver disclosure required under the EFT Code?

ASIC has called for feedback on the issue of Code members meeting disclosure requirements (terms and conditions, receipts, etc) by providing a hyperlink to the relevant information. The Consultation Paper notes on the one hand the increased risk of phishing and other Internet scams this would represent, but on the other hand the speed and simplicity of this approach.

The use of hyperlinks is extremely dangerous and confusing for consumers and consumer stakeholders oppose the use of hyperlinks in any circumstances in the Internet banking context. The use of hyperlinks in EFT Code disclosure is likely to undermine other consumer messages on phishing and scams, where consumers are told not to trust hyperlinks, and many institutions now tell their customers that they do not use hyperlinks.

Consumer stakeholders note that in other contexts, hyperlinks may be appropriate. For example ASIC is considering the use of hyperlinks in relation to the issue of a prospectus.[1] However, in the Internet banking / EFT context it is important that all regulators, financial institutions and consumer organisations send a consistent message regarding hyperlinks.

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[1] Australian Securities and Investments Commission, Facilitating online financial services disclosures, Consultation Paper 93, April 2008, <http://www.asic.gov.au/asic/asic.nsf/byheadline/IR+08-12+Facilitating+online+financial+services+disclosures>.

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