Submission: Facilitating electronic financial services disclosure

Consumer Action has provided a submission on the Australian Securities and Investments Commission’s Consultation Paper 224: Facilitating electronic financial services disclosure.

Our responses to the Consultation Paper’s proposals include:

  • Proposal A1: we broadly welcome steps to remove unnecessary obstacles to providing disclosure electronically as long as doing so does not remove the ability for consumers to choose to receive paper documents;
  • Proposal B1: We broadly support this proposal, but recommend RG 221 be amended to encourage FSPs to ask consumers to indicate how they would prefer to receive disclosure documents at the point that they are collecting contact information.
  • Proposal B2: we support providing class order relief allowing disclosure to be made via website or other electronic facility without seeking further consent, but only if the consumer has already nominated to receive disclosure electronically. This method of disclosure is not appropriate for consumers who have nominated their postal address for receiving disclosure;
  • Proposal C1: We support the proposal to grant class order relief to facilitate innovative PDSs, subject to reasonable restrictions;
  • Proposal D1: We support in principle steps to make it easier to deliver credit disclosure by electronic channels, though we would want to see specific proposals before reaching a firm position.

A full copy of our submission is available by clicking: Facilitating electronic financial services disclosure.

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