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

Q2 – Are there trends or developments that the Review Working Group should particularly consider in reviewing the EFT Code? What implications might these have for the regulatory scheme of the Code?

The convergence / confusion of consumer banking and business banking has significant implications. This issue is important because financial institution terms and conditions continue to be considerably harsher for those accounts not protected by the EFT Code. Terms and conditions provided by financial institutions are currently divided into Code compliant and non-compliant sections depending on the ‘business’ nature of the transaction. This issue may also have implications for the complexity of dispute resolution processes.