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

Proposal G4

G4Q1 Do you agree with the proposal for subscribers to provide information about the number, nature and resolution of unauthorised transactions? Please give reasons.
G4Q3 Do you agree with the proposal for ASIC to monitor compliance? Please give reasons.

We also propose that ASIC will also monitor compliance with specific EFT Code requirements. This will replace the current arrangements, which require subscribers to self-report on compliance with every obligation under the EFT Code. The focus of this compliance monitoring will be targeted and may change over time. Subscribers may be required to report information about other specific requirements as part of this targeted compliance monitoring. ASIC may also use other monitoring mechanisms such as shadow shopping exercises.

G4Q1 Do you agree with the proposal for subscribers to provide information about the number, nature and resolution of unauthorised transactions? Please give reasons.

Consumer stakeholders support this proposal.

G4Q3 Do you agree with the proposal for ASIC to monitor compliance? Please give reasons.

Consumer stakeholders support this proposal. Indeed, consumer stakeholders see targeted compliance monitoring as the key to improvements in the effectiveness of the Code, particularly in areas such as the effective use of internal dispute resolution. Consumer stakeholders support innovative, targeted compliance monitoring such as shadow-shopping. There is also strong support for the collection and analysis of consumer case studies from casework agencies, although this may have resource implications for some agencies that will need to be taken into account.





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