Financial Rights put in a short submission to ASIC regarding a modification they are making to Clause 21 of the ePayments Code. This modification makes it easier for financial service providers to disclose information electronically as a default without consumer consent. Our submission warned that not all consumers have reliable access to email, and they should be given a genuine choice as to how they prefer to receive disclosure documents. We also specifically recommended that any electronic disclosure should be accessible on all types of devices, and if a consumer wants a paper copy of their disclosure documents these must be provided free of cost.
