Submission to RBA regarding Review of Card Payments Regulation
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24 April 2015
The Consumer Action Law Centre (Consumer Action) and Financial Rights Legal Centre (Financial Rights) welcomed the opportunity to comment on the Review of Card Payments Regulation Issues Paper (the Issues Paper) published by the Reserve Bank of Australia (RBA).
In reviewing its card payments regulation, we urged the RBA to explicitly consider the impact of its regulatory actions on disadvantaged and vulnerable consumers. With these considerations in mind, our submission argued (among other things) that card payments regulation should:
- increase transparency of interchange fees and surcharging;
- promote competitive neutrality;
- lower interchange caps;
- replace weighted interchange caps with hard caps;
- appoint a regulator responsible for enforcement of payment surcharging rules;
- ban surcharging for low-cost payment methods; and
- ensure automatic routing of contactless transactions does not impair consumer choice.