Galexia

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

Q71 – What changes could/should be made to the way the EFT Code is written, designed and presented to make it a more user friendly and accessible document?

As suggested elsewhere in this submission, the EFT Code can be improved through shortening and simplifying the text. Some other minor improvements might also be considered:

  • Once the text is shorter, it may be able to move the endnotes to short footnotes or notes within the main text so that they can be read together;
  • Clauses 8 and 20 should be shortened and moved to the scope and definitions sections at the beginning of the Code, as this is a more appropriate location and it will be useful to have all scope and interpretation provisions in one location; and
  • Part B should be deleted (discussed above). This may allow the remaining Part A and Part C to be combined so that there is no need for the constant references to ‘Part X’ in the text of the Code.