Submission - Joint submission to the 2007 Review of the Electronic Funds Transfer (EFT) Code of Conduct to ASIC (May 2007)

Q12 – Should the requirement in cl 3.1 to provide written notification in advance of an increase in a fee or charge be replaced by another process? For example, should the notice appear in the national or local media on the day on which the increase starts?

There is no evidence that national media notices are an effective form of disclosure. Newspaper circulation in Australia is not keeping pace with population growth and English-language newspapers do not reach a large proportion of the population. Financial institutions are unlikely to use broadcast media to provide notice of increased bank fees, especially as their argument against the current notice requirement is essentially based on costs.

In practice, EFT Code notices are supplied as part of existing communication with customers (e.g. bank statements) and do not represent an additional burden on institutions.