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

Q66 – How should compliance be monitored? What alternatives to the current self-reporting survey should be considered?

Consumer stakeholders are sceptical about the usefulness of the self-reporting survey and annual report. This submission refers to, and agrees with the comments made in the Consumer Caseworker Submission in relation to the survey and report. However, there are other priorities for consumers in this review, and resources should be first be devoted to these issues. Hopefully the survey will be shorter and simpler following the proposed shortening and simplification of the Code in this Review.

The problems with current data collection are noted. This is chiefly an issue for financial institutions to resolve. However, consumer stakeholders note that improvements in data collection on complaints should be a higher priority than other areas of data collection.

Consumer stakeholders would be interested in discussing some form of independent monitoring, with perhaps reference to the experience with the Code Compliance Monitoring Committee of the Code of Banking Practice. In lieu of reviewing the compliance and monitoring provisions in detail at this time, a one-off independent evaluation of compliance (e.g. a one-off shadow shopping exercise) would be very helpful. This would provide invaluable information for the ongoing governance of the Code and for the next Code Review.