A Variation to the Access Regime for the ATM System: Conclusions – August 2012 4. Views Expressed During Consultation

The Bank requested submissions from interested parties by 13 July 2012. Five parties made submissions: an industry body representing banks (the Australian Bankers' Association); an independent ATM deployer (Cashcard); a body representing financial counsellors (Financial Counselling Australia); an ‘aggregator’ of ATM services for smaller participants (Indue); and a research centre (Centre for Rural Regional Law and Justice).

All five submissions supported the proposed variation to the Access Regime, noting that it would provide the Bank with greater flexibility to grant exemptions for otherwise prohibited ATM arrangements – where it is appropriate to do so – while retaining the criteria under which an exemption may be granted.

Nonetheless, two submissions raised several issues about the specific circumstances that have prompted the Bank's current review. At the same time as expressing support for the proposed variation, the Centre for Rural Regional Law and Justice urged the Bank to provide further guidance on how the expanded exemption power may be used. Similarly, Indue supported the draft variation to the Access Regime while raising concerns about using the extended exemption power in relation to the specific scheme proposed for very remote Indigenous communities.[1]


Indue's concerns were expressed on behalf of the Traditional Credit Union, for whom Indue provides transactional and electronic funds transfer services (including for the ATM system). [1]