Payments System Board Annual Report – 2006 Reform of Card Payment Systems

Over recent years, the Reserve Bank has implemented a number of major reforms to Australia's credit and debit card systems designed to improve efficiency and competition in the Australian payments system. These reforms have promoted more appropriate price signals to cardholders and merchants, improved access arrangements, removed restrictions on merchants, and increased the range of information available to users of the payments system. The rationale for these reforms has been extensively set out by the Bank in previous Annual Reports and in various consultation and other documents.[4]

While the reforms to the credit and debit card systems have been part of a package, they occurred at different times. The credit card system reforms were implemented in 2003 and 2004, and included: a lowering of interchange fees in the Bankcard, MasterCard and Visa credit card systems; measures to liberalise access; and requiring the removal of restrictions on merchants imposed by the credit and charge card schemes. In contrast, the reforms to Australia's debit card systems were not finalised until the first half of 2006. When implemented, the reforms to the debit card systems will see a lowering of interchange fees in both the EFTPOS and scheme debit systems, improvements in access arrangements for the EFTPOS system, and the removal of the rule that required a merchant to accept a scheme's debit cards if it accepted the scheme's credit cards.

Reform of the Credit Card System

The reforms to the credit card system reduced average interchange fees in the Bankcard, MasterCard and Visa credit card schemes from around 0.95 to around 0.55 per cent of the transaction value. They also required all credit and charge card schemes to remove their rules preventing merchants from charging customers a fee for paying by credit card (the no‑surcharge rule). The reforms also improved access by allowing participation by a new class of institution, known as a Specialist Credit Card Institution (SCCI), and promoted greater availability of information regarding interchange fees, average scheme merchant service fees and market shares.

Merchants' costs and prices

As a result of the reforms, merchant service fees for credit and charge cards have fallen substantially. The weighted-average merchant service fee for Bankcard, MasterCard and Visa credit cards in the June quarter 2006 was 0.89 per cent, well down from the 1.40 per cent immediately prior to the Bank's reforms coming into effect in November 2003 (Graph 3). This fall of around 50 basis points in the average merchant service fee is larger than the decline in interchange fees of 40 basis points, suggesting a strengthening in competition amongst acquirers for merchant business since the reforms were implemented.

Merchant service fees for American Express and Diners Club cards have also fallen since the reforms, given the competitive pressure from the other schemes and the removal of restrictions on merchants. Since interchange fees were lowered in the Bankcard, MasterCard and Visa schemes, the average merchant service fee in the American Express scheme has fallen from around 2.46 per cent to 2.28 per cent. The average merchant service fee for Diners Club has fallen from around 2.37 per cent to 2.27 per cent over the same period.

These declines in merchant service fees represent substantial savings to merchants. After taking account of changes in market shares, in the 12 months to June 2006, merchants' costs of accepting credit and charge cards were around $730 million lower than they would otherwise have been. These cost savings are flowing into lower prices for goods and services, although the flow-through is difficult to measure given the much larger changes in other costs that are occurring on an ongoing basis.

Prices to cardholders and competition

As expected the reforms have changed the effective prices facing users of credit cards. This has occurred in three ways: a reduction in the value of rewards programs; higher annual and other fees; and the introduction of surcharging by some merchants.

Since the reforms were implemented, the value of rewards points has been reduced. One measure of the value of these points is the amount that must be spent to receive a $100 shopping voucher. In 2003, this amount was, on average, around $12,400; today it is around $16,000 (Table 7). This change represents a reduction in the value of reward points of around 0.18 percentage points of the amount spent.

At the same time that the value of rewards points has been reduced, annual and other fees on credit cards – including those associated with rewards programs – have been increased. According to data collected by the Reserve Bank, average fee revenue per credit card account has increased from around $40 in 2002 to $70 in 2005.

Surcharging for credit card use has also increased over the past couple of years; recent surveys indicate that around 12 per cent of very large companies surcharge while around 2 per cent of small companies do so.[5] These surveys also suggest that many merchants are considering imposing a charge. Further, some merchants charge more for the more expensive American Express and Diners Club cards.

In addition to their effect on price signals to cardholders, the reforms have also had an impact on the type of credit card products offered in the market place. Prior to the reforms, competition amongst issuers largely focused on rewards programs, with issuers using these programs to attract spending on their cards. Now that issuers are receiving lower interchange revenue, cardholders who do not pay interest, but redeem rewards points, have become less profitable, notwithstanding the changes to the reward programs. This has encouraged some card issuers to focus more on attracting customers who use their credit cards to borrow, by offering them lower interest rates. While the development of the ‘low-rate’ market would have occurred in the absence of the reforms, the lower interchange revenue prompted issuers to reassess their product offerings.

Competition on interest rates has led both to a proliferation in the number of low‑rate cards available and sharp reductions in the interest rates on those cards, relative to the rates previously available. Credit cards are now available with on-going interest rates as low as 8.99 per cent, compared with an average of between 16 and 18 per cent prior to the reforms. Low-rate cards are now issued by all of the major banks, as well as several other existing participants and new entrants. These cards generally do not offer reward points but have both an interest-free period and lower annual fees than do the higher interest rate cards.

Growth of credit card use

Partly reflecting the changed price signals described above, growth in credit card spending has slowed over recent years (Graph 4).

While some slowing was inevitable from the rapid pace of growth experienced over the late 1990s, the decline in the generosity of rewards programs, increases in fees, and the introduction of surcharging by merchants have also played a role. Over 2005/06, the number of credit card transactions increased by around 7 per cent, while the value of transactions increased by around 9 per cent. Both these growth rates are substantially below the equivalent figures for debit cards, the first time this has been the case since 1997.

By value, the combined market share of American Express and Diners Club has increased from an average of 14.9 per cent in 2002/03 (prior to the reforms) to 16.5 per cent over the past financial year (Graph 5). The bulk of this increase occurred in the second quarter of 2004, when two of the major Australian banks commenced issuing American Express credit cards. By number of transactions, the combined market share of American Express and Diners Club was 12.4 per cent in 2005/06, lower than their share of the value of transactions. This reflects the higher average transaction value in these schemes compared to the Bankcard, MasterCard and Visa schemes.

The Bank continues to monitor carefully the market shares and average merchant service fees of American Express and Diners Club.

Regulatory developments during 2005/06

During the past year the Board made two changes to regulations affecting the credit card system. The first was an amendment to the interchange Standard so that a common interchange benchmark will apply to the MasterCard and Visa systems from 1 November 2006. The second was to exempt Bankcard from regulation, given its decision to close operations.

Prior to the move to a common interchange Standard, each scheme had a separate benchmark based on the costs of issuers in that scheme. The average interchange fee in each scheme was required to be no greater than the relevant benchmark. Under the amended Standard, a common benchmark will instead apply to each scheme.

This change was made in consultation with the industry. In February 2005, the Bank sought views from interested parties on the merits of a common benchmark across the Bankcard, MasterCard and Visa schemes. While views differed, a number of organisations noted that the scheme-specific benchmarks could give the scheme with the highest benchmark a competitive advantage in attracting issuers, because it could pay the highest interchange fees. This was particularly likely to be so if the higher benchmark reflected costs associated with particular characteristics of issuers' portfolios in the year in which the benchmark was determined, rather than intrinsically higher on-going costs peculiar to the scheme.

Following the initial round of consultation, in July 2005 the Bank released for comment a draft revised interchange Standard setting out a common benchmark. The Bank received seven submissions on the draft Standard, and held discussions with most of those making submissions.

The revised Standard, with minor modifications, was then determined by the Board and gazetted in November 2005.

The Board also made the decision to exempt Bankcard from regulation, given its announcement that it is to close in early 2007. Accordingly, the Bank's designation of the Bankcard system was revoked on 27 April 2006, with references to Bankcard in the common interchange Standard removed at the same time. The Bank made clear, however, that it expects Bankcard's current interchange fees to be maintained until the scheme is closed.

Reform of the Debit Card Systems

During the past year, much of the Board's work was devoted to finalising a major package of reforms to Australia's debit card systems. This package, which was announced in April 2006, involved:

  1. an Access Regime for the EFTPOS system, to complement the EFTPOS Access Code developed under the auspices of the Australian Payments Clearing Association (APCA);
  2. an interchange Standard for the EFTPOS system;
  3. an interchange Standard for the Visa Debit system; and
  4. a Standard requiring the removal of the ‘honour all cards’ and ‘no surcharge’ rules in the Visa Debit system.

MasterCard has provided an undertaking to the Bank to ensure outcomes in the MasterCard debit system equivalent to those required by the Standards applying to the Visa Debit system.

Australia's debit card systems

There are two types of debit card systems in Australia; the EFTPOS system operated by Australian financial institutions, and systems operating under the brands of MasterCard and Visa (the scheme debit systems). Both types of system allow cardholders to make payments to merchants from a deposit account held at an authorised deposit-taking institution, while the EFTPOS system can also be used at some merchants to withdraw cash.

The EFTPOS system currently accounts for around 85 per cent of debit card transactions in Australia. It is not able to be used, however, in situations in which a PIN cannot be entered into a secure PIN pad, such as over the internet or telephone. It is also a purely domestic system, so that the EFTPOS system cannot be used to make payments overseas. The system is built around a series of bilateral business contracts and technical links between issuers and acquirers. Interchange fees are paid by the issuer to the acquirer and are typically in the range of 18 to 25 cents per transaction.

In the scheme debit card systems, a cardholder authorises a transaction at a merchant by signature. Scheme debit cards use the processing infrastructure of the international card schemes, and can be used to undertake transactions over the internet and telephone (without a signature authorisation), as well as overseas. In contrast to the EFTPOS system, interchange fees are paid by the acquirer to the issuer and average around 0.55 per cent of the transaction value. The Visa Debit system has been operating in Australia for many years, while the first MasterCard debit card in Australia was launched in late 2005.

Policy issues

The Bank's reforms have focused on three issues: interchange fees; access arrangements; and restrictions that prevented a merchant from choosing freely which payment methods to accept.

One consequence of the significantly different interchange fees in the EFTPOS and scheme debit systems is that issuers have priced scheme debit transactions to cardholders more attractively than they have priced EFTPOS transactions. This is despite the EFTPOS system having lower resource costs, reflecting lower fraud, shorter transaction times and lower costs of processing. The Bank has been concerned that the competitive position of the two types of debit cards was being heavily influenced, not by the relative merits of the two types of cards, but rather by interchange fees which themselves are not subject to the normal forces of competition. The Bank has had similar concerns about the competitive position of the EFTPOS system relative to the credit card system.

The issue of access to the EFTPOS system is long standing, and has been reviewed by the Bank and the Australian Competition and Consumer Commission (ACCC). Typically, in other countries, there is a single point of entry to a payment system for new participants. In contrast, given that the Australian EFTPOS system is based on bilateral interchange contracts and bilateral physical connections, entry can require negotiations with all existing participants, each of whom might have different technical and business requirements. Furthermore, the existing participants may have little incentive to facilitate the entry of a new participant, particularly if the entrant is likely to be a direct competitor in at least some business lines.

The third issue has been the restriction placed on merchants in deciding which payment methods to accept by the so‑called honour all cards rules imposed by the MasterCard and Visa schemes. Under these rules, whenever a merchant agrees to accept credit cards issued under the MasterCard or Visa brands, it is required to accept the scheme's debit cards as well. This has meant that competitive forces could not bear directly upon the price, or acceptance by merchants of the scheme debit product.

Collectively, these arrangements distorted the relative competitive positions of the EFTPOS and scheme debit systems. For domestic point-of-sale transactions, which represent the largest segment of card-based transactions, the two types of debit systems are highly substitutable. Scheme debit, however, had a competitive advantage over EFTPOS because merchants were forced to accept the card when they made the decision to accept scheme credit cards, and the higher scheme debit interchange fees were encouraging issuers to issue and promote scheme debit in preference to EFTPOS. This raised the possibility that, over time, the scheme debit systems might displace the EFTPOS system, not because of differences in services to merchants and cardholders, but because of the combined effect of the schemes' honour all cards rules and differences in interchange fees.

The reform process

The Bank began examining interchange fees and access arrangements for Australia's debit card systems in its work with the ACCC in 1999. That work resulted in the publication by the Bank and the ACCC of Debit and Credit Card Schemes in Australia: A Study of Interchange Fees and Access (the Joint Study) in October 2000.

Following the release of the Joint Study, both the industry and the Reserve Bank began working to address issues concerning debit cards raised in the report. The Bank initially conducted discussions with Visa and issuers of Visa Debit cards with a view to agreeing voluntary changes to interchange fees. However, the Board decided in February 2004 to designate the Visa Debit system, to ensure a transparent process that would allow comment on proposals by all interested parties. The Bank did not, however, immediately proceed to propose a particular interchange Standard for Visa Debit, given that this issue needed to be considered together with proposals for changes to interchange fees in the EFTPOS system – and, at the time, there were signs that participants in that system were close to agreeing on reform of these fees.

Agreement was then reached by an industry group to set interchange fees in the EFTPOS system to zero. In February 2003, the group took this proposal to the ACCC which, after issuing a draft determination rejecting the application due to concerns about access, approved the proposal in December 2003. This was done in the expectation that the issue of access would be adequately addressed either by the industry or the Bank. A group of merchants then challenged the ACCC's decision in the Australian Competition Tribunal (ACT), with the ACT over‑turning the ACCC's authorisation in May 2004.

After closely examining the ACT's ruling, the Bank remained of the view that a lowering of interchange fees in the EFTPOS system would be in the public interest. It therefore designated the EFTPOS system in September 2004, noting that there was little further prospect of industry reform of EFTPOS interchange fees. The designation was followed in October 2004 by a legal challenge in the Federal Court by a group of merchants to the validity of the designation. While this case was being decided the Bank released, in February 2005, draft Standards for interchange fees in both the EFTPOS and Visa Debit systems, and a Standard that would require the removal of the honour all cards rule in the Visa system. It noted, however, that final decisions would not be made until the legal challenge to designation of the EFTPOS system was decided.

At the same time, the industry (under the auspices of APCA) was developing an Access Code for the EFTPOS system. After two years, the industry indicated its agreement to a Code that was acceptable to the Bank. APCA, however, asked the Bank to consider giving regulatory certainty to the proposed cap on the price of establishing a new connection, contained in the Code, through an Access Regime under the Payment Systems (Regulation) Act.

After the case challenging designation of the EFTPOS system was decided in the Bank's favour in November 2005, the Bank issued a second consultation document in December 2005 setting out a draft Access Regime and making an amendment to the draft Standard on EFTPOS interchange fees. Following consultation on the new proposals as well as on the earlier components of the package, the Bank announced its final reform package on 27 April 2006. Throughout the process, 37 submissions were received on the Bank's proposals, and the Bank met with 15 parties – in some cases more than once – who took the opportunity to discuss submissions with the Bank.

Interchange Standards for EFTPOS and Visa Debit

The Standards on interchange fees will narrow the difference in interchange fees between the EFTPOS and scheme debit systems, on an average transaction, from around 60 cents currently to around 20 cents. In the Bank's view, this will better promote competition between credit cards, scheme debit cards and EFTPOS based on the benefits that the various cards offer to cardholders and merchants, rather than on the basis of interchange fees that are not subject to normal competitive pressures.

The EFTPOS interchange Standard imposes a cap and floor on interchange fees in the EFTPOS system for all transactions not involving a cash‑out component. The purpose of the floor is – in conjunction with non‑discrimination provisions in the EFTPOS Access Regime discussed below – to limit the scope for negotiations over interchange fees to be used in a way that weakens competition in the system, including from new entrants. In particular, it removes the possibility that new entrants might be offered an interchange fee that significantly disadvantages them compared to existing participants, thereby making it difficult for them to compete.

Interchange fees for EFTPOS transactions with no cash‑out component will fall to between 4 and 5 cents per transaction from 1 November 2006, from an average of around 20 cents currently. Interchange fees on EFTPOS transactions involving cash out are not subject to the Standard – the issue of whether there is a separate fee for cash‑out transactions, and if so what this might be, remains a matter for negotiation between issuers and acquirers.

The Visa Debit interchange Standard imposes a cap on the weighted-average interchange fee in the Visa Debit system. The Board provided both MasterCard and Visa with the opportunity to agree voluntarily to set interchange fees for their debit cards in line with this Standard. In the event, MasterCard provided the Bank with an enforceable undertaking that will cap the weighted average of MasterCard debit interchange fees at the same level as for Visa. Visa did not provide the Bank with such an undertaking, and the Visa Debit interchange Standard was gazetted on 7 July 2006.

As a result of these reforms, interchange fees in the Visa and MasterCard debit systems, which are paid to financial institutions that issue the schemes' cards, will fall significantly from 1 November 2006. Based on currently available information, the weighted-average interchange fee in each scheme is expected to be no more than around 15 cents per transaction, down from around 40 cents currently.

Access Regime for EFTPOS

The Access Regime for the EFTPOS system is relatively limited in nature, and is designed to complement the EFTPOS Access Code developed by APCA. It sets a cap on the price that an existing participant can charge to establish a new connection, and sets out provisions designed to help ensure that negotiations over interchange fees cannot be used to frustrate entry. Other important aspects of entry are covered in APCA's Access Code. These include providing new and existing participants with the right to establish direct connections with participants in the EFTPOS system, and setting a time frame for the establishment of connections and the completion of required testing.

The Access Regime was gazetted and came into force on 13 September 2006, following the formal adoption of APCA's Access Code by all existing direct connectors in the EFTPOS system on 8 September 2006.

Removing restrictions on merchants in the scheme debit systems

The ‘honour all cards’ Standard for the Visa Debit system requires that the tying of acceptance of Visa credit and debit cards be removed by Visa. It also requires that Visa Debit cards be identified both visually and electronically, to allow merchants to decline acceptance of either one if they so choose. Electronic identification must be possible from 1 January 2007, while visual identification must be possible for all new cards issued from this date onwards – with all Visa Debit cards on issue required to be visually identified by 31 December 2009. Both MasterCard and Visa were given the opportunity to agree voluntarily to these changes; only MasterCard opted to do so.

Automated Teller Machines

During 2005/06 the Bank continued to monitor work by participants in the ATM industry to address the issues of ATM pricing, and the arrangements under which potential participants gain access to the system.

The Australian ATM system is built around a series of bilateral interchange agreements and linkages. If a cardholder uses an ATM that does not belong to his or her financial institution, that institution pays the ATM owner a fee known as an interchange fee. This fee averages around $1 per withdrawal. A small number of card issuers absorb this cost and do not explicitly pass it on to their customers. Most, however, charge a ‘foreign fee’, which is typically either $1.50 or $2 per transaction.

The Bank has previously noted two concerns with these arrangements. The first is that interchange fees, which underpin foreign fees, are not subject to the normal forces of competition and, in the past at least, have been well above the cost of providing the service. The second is that, as in the EFTPOS system, the bilateral architecture of the system complicates entry for parties wishing to participate directly, rather than through gateway arrangements.

For some time, participants in the ATM industry have been exploring options to address these concerns. However, obtaining the agreement of all parties to an alternative set of arrangements has been difficult. Initially, there was some support from banks to move to a system in which the ATM owner charged the customer directly, but support amongst the banks for this approach has waned through time. In contrast, non-financial-institution owners of ATMs typically continue to support the direct charging model. Reflecting the difficulty of developing an alternative model, the Australian Bankers' Association wrote to the Bank in 2005 asking for some guidance on possible ways forward.

The Bank subsequently met with participants in the ATM system and other interested parties to seek their views on both the need for reform and how any reforms might be pursued. Following this meeting, the Bank recommended that the industry focus on three issues.

The first is liberalising access arrangements in the ATM system just as access arrangements to the EFTPOS system have been liberalised. The second is to explore the possibility of moving to a common interchange arrangement among all participants. As in the EFTPOS system, negotiations over interchange fees can significantly complicate access and it is important that bilateral negotiations over interchange fees cannot be used in a way that adversely affects access or competition. The third is to ensure that there are no restrictions on the ability of ATM owners to levy a direct charge if they wish to do so.

The industry has been working on these issues over the course of 2006, with a view to clarifying access arrangements and identifying any impediments to direct charging. A steering group established by the industry to conduct this work recently provided the Bank with a preliminary report, and is continuing to examine these issues.

Purchased Payment Facilities

Under Part 4 of the Payment Systems (Regulation) Act the Board has regulatory responsibility for purchased payment facilities – other than those issued on a wide basis, with deposit-like characteristics, and for which any unused stored value is redeemable on demand in Australian currency. Responsibility for the latter was transferred to the Australian Prudential Regulation Authority (APRA) in 2000.

In 2005, the Board determined that an electronic gift card proposed by Westfield for use only in its shopping centres was not subject to the Payment Systems (Regulation) Act because of its limited nature and purpose. At that time the Bank indicated that – in conjunction with the Australian Securities and Investments Commission (ASIC), which has consumer protection responsibilities in this area – it was examining the possibility of widening its existing class exemptions, announced in 2004.

In November 2005, ASIC decided that gift cards, pre-paid mobile phone accounts, loyalty schemes and electronic road toll devices would not be subject to certain provisions of the Corporations Act 2001. Consistent with this, the Bank announced in April 2006 that the Payment Systems (Regulation) Act would also not apply to these facilities. The specific exemption granted to the Westfield gift card facility became redundant and was revoked.

The Board also broadened the range of other facilities to which the Payment Systems (Regulation) Act would not apply. These now include facilities where the total amount outstanding is less than $10 million, up from $1 million previously. This revised limit is consistent with the threshold set by ASIC in its definition of ‘low‑value’ non-cash payment facilities, which were granted regulatory relief by ASIC in 2005.

Scrutiny of the Bank's Procedures and Policies

Over the past year or so, the Board's policies and the way in which the Bank carries out its payments system responsibilities have been subject to close scrutiny by various parties. The scrutiny has involved: a major legal case in the Federal Court; assessment of the case for merits review as well as judicial review of the Bank's decisions; and a two-day special hearing on payments system reform by the House of Representatives Standing Committee on Economics, Finance and Public Administration.

In November 2004, a group of merchants sought a judicial review in the Federal Court of the Bank's decision to designate the EFTPOS system as a payment system. The merchants alleged that the Bank had: misinterpreted and acted outside its powers; not taken into account the correct matters in coming to its decision; and acted unreasonably in reaching the decision that it was in the public interest to designate the EFTPOS system. In all, it was claimed that the Bank made more that 70 separate errors in reaching its decision. Preparation of the defence consumed a large amount of the time of the Bank's senior staff over many months and involved the discovery and cataloguing of more than 10,000 separate documents, many of which contained information confidential to third parties.

The case was heard over four weeks in May and June 2005, and a decision in the Bank's favour on all claims was handed down in November 2005. Costs were awarded in the Bank's favour.

In addition to judicial review, a number of organisations have argued that the Bank's decisions under the Payment Systems (Regulation) Act should be subject to merits review. In submissions to the Taskforce on Reducing Regulatory Burdens on Business, it was argued that affected parties should be able to seek a review of the merits of the Bank's decisions by a body such as the Administrative Appeals Tribunal or the Australian Competition Tribunal. Some of the submissions also argued that the Bank's powers should be restricted.

In its report issued in April 2006, the Taskforce recommended that administrative decisions made by government bodies should be subject to merits review. In its response in August 2006, the Government accepted this recommendation, but indicated that decisions made by the Bank about the operation of the payments system were either policy or legislative in nature, and thus would not be subject to merits review.

The House of Representatives Standing Committee on Economics, Finance and Public Administration also devoted considerable time to the Bank's reforms of card payment systems over the past year, holding two days of public hearings in May 2006, with testimony from the Bank, card schemes, financial institutions, merchants, consumers, consultants and academics.

While the Committee recognised the wide range of views, it was broadly supportive of the Bank's reforms, judging that the benefits outweighed the alleged disadvantages. It accepted that interchange fees are not determined under competitive conditions and that it was logical that falls in merchant service fees resulting from lower interchange fees would flow into lower prices for consumers. It also supported abolition of ‘no surcharge’ restrictions. After hearing extensive evidence from all the interested parties, the Committee concluded that the reforms had not inappropriately advantaged American Express and Diners Club, arguing that it was important to recognise differences in the way the various schemes operate.

The Committee also considered submissions arguing that the reforms should be formally reviewed by a separate body, such as the Productivity Commission, rather than by the Bank, which plans a comprehensive review beginning in 2007, five years after the credit card reforms were announced. The Committee did not accept these arguments, concluding that the Bank should conduct the review of its reforms and that it is well qualified to do so.


See, for example: Debit and Credit Card Schemes in Australia: A Study of Interchange Fees and Access, Reserve Bank of Australia and Australian Competition and Consumer Commission (ACCC), October 2000; Reform of Credit Card Schemes in Australia: IV Final Reforms and Regulation Impact Statement, Reserve Bank of Australia, August 2002; and Reform of the EFTPOS and Visa Debit Systems in Australia: Final Reforms and Regulation Impact Statement, Reserve Bank of Australia, April 2006. [4]

East and Partners Pty Ltd report to the Reserve Bank of Australia, ‘Australian Merchant Acquiring and Cards Markets’, August 2006. [5]