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

Q34 – To what extent is unreasonable delay in notification of security breaches by account users currently an issue? Please provide on the frequency and cost of such delays, if possible. (You may wish to provide this information on a confidential basis.)

Consumer stakeholders are not in a position to provide new data on this issue. There is some concern that increased charges by financial institutions for replacement cards / tokens may act as a disincentive for low income and disadvantaged consumers to report security breaches quickly. Consumers spend further time searching for missing cards / tokens in order to avoid replacement fees. Financial institutions should be discouraged from introducing / increasing these replacement charges if they wish to also rely on the ‘unreasonable delay’ provisions in the Code. The final paragraph of Clause 5.5 is relevant here, but there is no available data on its use.





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