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Human Services (Enhanced Service Delivery) Bill 2007

CHAIR —Thank you very much for being here this afternoon. Before I invite my colleagues to ask questions, would either of you like to make an opening statement?

Mr Bell —Thank you. ABA welcomes the opportunity to appear before the Senate Standing Committee on Finance and Public Administration. Banks are of course the major players in payment systems and distribution of financial services in Australia, and they support government service providers and their clients. The provision of financial services is highly regulated in Australia. One of the key requirements is that a bank must know the identity of the person with whom they are dealing. Identification obligations are key to the prevention of money laundering, terrorist financing and other serious financial crimes. Just like the AML legislation, the bill will have major impacts on banks’ customers and on our members, which we would like to highlight briefly to you today.

Banks and other institutions in Australia now face even stronger obligations under the new Anti-Money Laundering and Counter-Terrorism Financing Act. The new obligations cover a much broader range of services, requiring, on the basis of an assessment of money-laundering risk, new identification for potentially a very large number of customers, as well as ongoing ‘know your customer’ activities for the maintenance and possible augmentation of this information. The importance of the AMLCTF Act will become relevant in just a moment.

The ABA’s interest in the bill is very narrowly focused. If the customer chooses to offer an access card to satisfy the government’s identification requirements under AMLCTF legislation, we would like to be able to accept it. There appear to be two possible obstacles in the bill to this occurring. Firstly, if the card is offered by a customer, a record of the access card needs to be taken as required by the AML legislation, as is the case for other documents produced for identification purposes. This results in a potential conflict between the AML legislation and the bill.

CHAIR —Mr Bell, I am sorry to interrupt your opening statement—and I do this guardedly—but, when you say ‘a copy of the card’, do you mean a copy of what is in the chip or a photocopy of the card itself?

Mr Bell —I am sorry; I missed that question.

CHAIR —You said there must be a record.

Mr Bell —A record of the card.

CHAIR —You said you needed to see a copy of that? Maybe I missed it. Could you just go back to the bit where you said that, and say it again. Maybe I am losing my concentration, Mr Bell, but could you please read that bit again.

Mr Bell —Yes, sure. What I said was—sorry, Tony; do you want to elaborate?

Mr Burke —Yes. It could be either a photocopy of the card, which is commonly the case for a driver’s licence, or a record of the card, which could simply be taking the number of the card and recording that.

CHAIR —Okay. So it is not an electronic copy—

Mr Bell —No.

CHAIR —I just wanted to make that clear.

Senator FORSHAW —But, because it will have a photograph on it, it is—

CHAIR —We will get to that in a minute. I am sorry, Mr Bell.

Mr Bell —That is okay. This results in a potential conflict between the AML legislation and the bill. Clause 57 of the bill prohibits the unauthorised copying and making records of the access card number, photograph and signature. The government’s response to this has been that the prohibition does not apply if the customer consents in writing to the recording. However, this requirement will result in more paperwork and time-consuming processes for bank customers. It will also cost more to implement a new business process to do this. We provided an amendment to the minister to resolve the record-keeping problem while ensuring that the key privacy aspects of the bill are maintained.

The second problem flows from offences in clauses 45(2) and 46(2) of the bill, which prohibit a statement that can be interpreted that a person is being asked to produce their access card for identification. Given that banks currently ask for other forms of identification as part of the 100-points check, customers may mistakenly think the same demand has been made for the access card when in fact banks have not done so. In fact, widespread exceptions to the access card will mean that individuals will have fewer documents in their wallets which might have been used for the 100-points check—that is, the probability of an access card being offered for proof of ID will increase as it is rolled out.

This was acknowledged by the government, which has now attempted to correct the problem in the explanatory memorandum. The EM now says that a person will only be taken to have required the production of an access card if they ‘provide no other reasonable option for a card owner to prove they are who they say they are’. Our concern is that, by including these words in the EM, there is a risk that a court may not take these comments into account when interpreting the act. Our request is that words to a similar effect to those that have been put in the EM are put in the act.

Finally, we are concerned that the bill in its current form may place ordinary bank staff complying with AMLCTF regulation at risk of prosecution or other penalties. Thank you.

CHAIR —Your primary issue here is with ensuring the integrity of the access card as a form of identification.

Mr Bell —Our primary issue at this stage is the potential conflict between the AML legislation and the proposed bill.

CHAIR —In your submission, you talk about the objects and purposes of the act being potentially in conflict. I need your help here, because I am not sure why this necessarily conflicts. It reads:

(1)   The objects of this Act are:

(a)   to reduce the complexity of accessing *Commonwealth benefits, particularly for those who are most in need of assistance; and

(b)   to facilitate a more convenient, user-friendly and reliable method of accessing Commonwealth benefits; and

(c)   to reduce fraud on the Commonwealth in relation to the provision of Commonwealth benefits; and

and we have heard a lot about that—

(d)   to improve access to Australian Government relief in emergency situations; and

the government has spoken about that, both in estimates and the other day in Sydney—

(e)   to permit access card owners to use their access cards for such other lawful purposes they choose.

It then says:

(2)   It is also an object of this Act that access cards are not to be used as, and do not become, national identity cards.

Then in 7 it goes on to say that the purpose of the act is to facilitate the provision of social welfare benefits. What do you see the conflict as being? What is the conflict between the objects and the purposes there?

Mr Burke —I think you are referring to an earlier submission on the exposure draft. Is that the case?


Mr Burke —The potential inconsistency that we noticed there between objects and purposes has to a significant extent been rectified in the bill. The conflict to which Mr Bell was referring is between the AMLCTF legislation and the bill as it stands, and we think that that conflict still exists.

CHAIR —Now I am with you.

Senator LUNDY —I wanted to draw out a bit more information about this conflict of interest. You talk about the request of banks of a customer to provide 100 points check. The logical response of a customer is to say, ‘Will this do?’ What your submission says to me is that in that case you want to have it made very clear in the legislation that, when a customer responds to your request for 100 points of identity by offering the access card, that will render the banks completely clear of any breach, offence or liability under this act. Is that correct?

Mr Bell —That is correct—so long as the law has been followed. And the banks will follow the law.

Senator LUNDY —Yes. I am working on the basis of what you describe, which is your general request of a customer for those 100 points. That would work well. You say that if you moved the words from the explanatory memorandum into the bill that would make that quite explicit that you were not committing an offence.

Mr Bell —Yes.

Senator LUNDY —But what if the aspiration of this government with this access card was achieved and it did in fact replace all of those other primary sources of identification? Say we are in Queensland and it has replaced the driving licence as well. Would that insertion into the act also prevent the banks from committing an offence under the bill if that meant that I as your humble Queensland customer only had an access card?

Mr Bell —So long as the institution was following the law, yes.

Senator LUNDY —But your question is ‘give us 100 points’. By virtue of the system, the only 100 points I could give you is the access card, so you are in the same spot.

Mr Bell —There are many other forms of identification, such as passports, birth certificates and credit cards. You are saying that the driving licence may be replaced, but I do not know anything about that. There are many other forms of identification.

Senator LUNDY —I am speculating, really, but I am trying to make a point.

Mr Bell —Sure. In other words, there are many other forms of identification that could be used to arrive at 100 points, if that system remained in place.

Senator LUNDY —If that were the case, what is your understanding of how many identification points, if any, will be attributed to the access card, either on its own or in conjunction with other forms of ID?

Mr Burke —That has not been determined at this stage. There are two issues there. Firstly, the 100 points check itself is under review. It remains into force until the identification obligations under the new AMLCTF Act come fully into force. It may continue as is; it may be replaced. There has been talk of a wallet test,  which would have a gold, silver or bronze—

Senator FORSHAW —A what?

Mr Burke —A wallet test, as in a back-pocket wallet. If that was to be the case then there is talk of there being a gold, silver or bronze standard of identification. But if the 100 points check were to continue it would be AUSTRAC, the AML regulator, who would determine the number of points. There has been no discussion, to my knowledge—

Senator LUNDY —When you say that is being reviewed, is AUSTRAC reviewing that 100 points check?

Mr Burke —AUSTRAC set the rules which give effect to the primary obligations in the legislation. There would need to a rule which provided for a 100 points check or a wallet test or something else.

Senator LUNDY —So you anticipate that AUSTRAC would be the entity that would determine how many points, if any, will be attributed to the access card?

Mr Burke —Yes, as I understand it.

Senator FORSHAW —Can you remind me, because it is some time since I actually opened an account at a bank—I have got quite a few credit cards, mostly with little debts on them—

Senator LUNDY —Too much information!

Senator FORSHAW —That is right. I am just trying to remember how the 100 points system works. Do you have category A and category B? I think that applies for a passport—you must produce one of a certain range of documents, such as a birth certificate, and then there is a broader list of documents that may not be government issued documents. Can you remind me about that?

Mr Burke —It is quite a long list at the moment. There are documents which are produced for identification purposes. None of these are identity documents, by the way. A passport is not an identity document; a drivers licence is not an identity document. But those documents can be used for identification purposes.

CHAIR —The access card is not an identity document either.

Mr Burke —No, I am not saying that. We understand that.

Senator FORSHAW —I understand there is a range of documents. What I am trying to understand is what is the relative status, if you like, between things like passports, birth certificates et cetera. Am I correct that you must produce a document out of one group and one or two documents out of another? Just remind me about that.

Mr Burke —At the moment there is no single document which will provide 100 points. One would need a passport, which carries a high value, and another document to get to 100 points.

Senator FORSHAW —Yes, but it would be a passport—

Senator LUNDY —A birth certificate or a drivers licence.

Mr Bell —The question is: do you need a passport as well as something else? Do you need a drivers licence?

Mr Burke —There are two categories of document.

Senator FORSHAW —Yes. In other words, you cannot get it by having 10 credit cards, theoretically. The fact that you have got the 10 credit cards means you have already provided it, but you have got to have—

Mr Bell —A particular form of documents.

Senator FORSHAW —The relevance of this is that the access card, one would assume, would go into that group of documents which were given a much higher status than membership of, for example, the local leagues club.

Senator LUNDY —I think that is the point of contention: how many points will it be given under that system? I understand, from the evidence we have heard, that AUSTRAC will assign that point value for a 100 points check system—if any value at all.

Senator FORSHAW —What I am positing is that if the access card is going to be of some equivalent value to a passport or a birth certificate, which may not be readily obtainable, or a drivers licence—maybe of more value than a drivers licence—and if a person does not have a drivers licence or a passport and has trouble getting their original birth certificate then the document that is left is the access card. What you are putting to us is that if that is volunteered, as distinct from being requested, then you should be able to accept it and copy it without fear of breaching the act. The other question then is: would the industry want to be able to list the access card—and I appreciate what you said about AUSTRAC reviewing all this—as one of the documents that could be provided, albeit voluntarily, to prove identity and gain points?

Mr Bell —Yes, if it is available—so long as the law is followed.

Senator FORSHAW —I understand that that is a crucial issue also because it goes to the primary object of the act. I cannot think of any legislation in which one of the objects is to not do something. The object of legislation is always to promote something or achieve something, not to negative it.

Senator LUNDY —Do you want to respond to that?

Mr Burke —Again, there has been no determination as to points. That could not be made because the value would depend on what information was on the card, and that has not been determined completely, either.

Senator FORSHAW —I can envisage it becoming a requirement to use an access card to get a passport because they are both documents issued by the government and they both go to identity. Ipso facto, you start to wonder why you should not be able to ask for an access card if you can ask for a passport. Anyhow, that is just a comment.

Senator LUNDY —Going back to the taking of copies of the access card: did I hear you correctly when you said that, if you photocopy it or physically record the number, that does not constitute an electronic replica or copy of the card?

Mr Burke —No, that would not involve accessing information electronically.

Senator LUNDY —Do you think it is an offence under the act to take a photocopy of the card?

Mr Burke —We believe so.

Senator LUNDY —So you want that fixed as well?

Mr Burke —Yes.

Senator LUNDY —That presumes that it is part of the points check or whatever takes place.

Mr Burke —Correct.

Senator LUNDY —You say that you do not want to see function creep so explicitly prohibited as to not allow some reasonable expansion of uses. That is certainly a point of contention in the political debate. Have you, as a commercial entity, or any of your members ever considered rolling out a smartcard for your customers for the purpose of a multitude of financial or other services?

Mr Burke —Are you asking whether the ABA has considered that?

Senator LUNDY —Any of your member organisations—any of the banks.

Mr Burke —Some banks have smartcards already—

Senator LUNDY —St George is one, I think.

Mr Burke —one of which was mentioned in the Hansard of the estimates hearing. Banks are rolling out smartcards over time, according to the needs and circumstances of their own customers. There is no industry standard on this. It has been driven by a range of needs, including customer demand for enhanced services, fraud prevention and the like.

Senator LUNDY —For the banks that have rolled out smartcards, are you aware of the standards that are used on those cards?

Mr Burke —I am afraid not.

Mr Bell —The point is that no industry standard applies.

Senator LUNDY —No, that is right.

Mr Bell —Each bank makes its commercial determination.

Senator LUNDY —We got some information about the standard that the Australian government has chosen for the smartcard. I am interested in the extent to which it consulted the banking industry about standards. It raises the prospect of interoperability between banking smartcards and this smartcard and the use of that private space for expanded commercial purposes et cetera. Perhaps you could take that on notice and get back to the committee.

Mr Burke —Is your question about the technical standards?

Senator LUNDY —Yes, and about whether any of your members have been approached by the government on the issue of the interoperability of smartcard systems. On the issue of function creep, there is quite a bit of commentary in your submission about not wanting that to be restricted. There is obviously political pressure on the government to restrict function creep. Is your point that we should not permit function creep to impinge on the commercial opportunities of the private section of the card, or is your point that you believe, as an organisation, that the functions should be expanded within the public domain? I have to say that it is the latter that is my interpretation of your submission. If so, why?

Mr Burke —Neither of those really. I understand why there would want to be a policy statement that there should be no function creep, and one would do that for all sorts of reasons, not just on the grounds of public policy; the cost would be another good reason. Our point was to say: let’s not define function creep so strictly that it would prevent technical opportunities to the advantage of all.

Senator LUNDY —I would like to respond to that point that you have made by saying that a lot of the contention has been to permit function creep without parliamentary scrutiny or indeed the opportunity to amend the legislation via debate not just disallowance. So the legislation could always be amended.

We heard some evidence from Sony, I think, in Sydney, who talked about the expansion of that private use of the card and said that really all that was required in some circumstances was a commercial entity to purchase the application licence and the software necessary to allow people to put additional functionality on the card. Would that be something that the banking industry would be contemplating if this access card were rolled out? Would any of your members, to your knowledge, be interested to expand that private space on the card to deliver financial services through their institution?

Mr Burke —I have heard no discussion on that.

Senator LUNDY —But it would be possible.

Mr Burke —With the technology that you are suggesting? Possibly, but I do not have any knowledge of—

Senator LUNDY —I do not know if you can take that on notice. Maybe it is related to the standards and if the standards are similar. But my understanding of the technology and the private space on the card is that the proposal we have before us would permit a commercial entity to purchase the development application needed to add more functionality on the card. I guess I am looking for confirmation or not. I think it is a very important question for the private sector in contemplating this model and it has a big impact on our considerations about this model.

Mr Burke —Yes.

Senator STOTT DESPOJA —Good afternoon, gentlemen. I am just reading through the comments about protection of privacy that you have made in your submission. You acknowledge that the commissioner will be releasing both an issues paper and a discussion paper during the next 12 months but, given the reporting date for the ALRC privacy inquiry, it is unlikely that any of the recommendations can be incorporated into planning for the access card. So your recommendation is that consideration be given to extending the registration process for the card until after 1 July 2008. That would obviously satisfy some of your concerns in relation to incorporating privacy and security issues. Is that a sufficient time line?

Mr Burke —Yes.

Senator STOTT DESPOJA —You have addressed the issues of points identification. I was going to ask about that, given that it does look like the government is phasing it out. I was wondering what impact it would have on the banking sector, but I think you have given us some ideas on that. The next thing I want to ask about is the idea that the government has talked about of providing emergency relief and payments through the card. You make a really interesting point in here about the fact that you acknowledge that there is merit in such an initiative but there is also a risk of potential fraud and money laundering if the person committing the crime has been able to get through the registration process without adequate checking. Do you want to elaborate on that? Also, I want to know what your views are in relation to the delay until 2010 in the document verification service starting up. Does that give you some concerns about verifying documentation that would actually ensure that people get into the register in a way that is proper?

Mr Burke —In relation to emergency payments, it had been our understanding that post that submission, which was from July last year, there would be consultation on the detail of an emergency payments mechanism. That has not occurred at this stage. All we know is that there is an intention to do it. So I have to say that our thinking has not really matured at this stage on how it might work, what the risks might be and how they might be overcome. I think we at that stage signalled our interest in such consultation, but that has not yet occurred.

In relation to the registration process and the DVS, we are on the record as saying that we welcome the DVS and we would further welcome an opportunity as part of the private sector to engage with the DVS. As to timing, I have not seen an announcement on that recently. As to how that might affect the registration process, it would be difficult for me to speculate on.

Senator STOTT DESPOJA —I think it came to light in the estimates process that we were looking at a delay until 2010. That is my understanding. Going back to the issue of the personal space on the card, I am a little obsessed with this clause 33A, which is legislated for in this particular bill but with no detail. It is just allowed for and then there is nothing. I am just wondering if the ABA has a position on whether, if we took that section out and dealt with it in more detail, say, at the second tranche of legislation, that is something you would have a problem with. We could legislate essentially for the card in its current form, with the information areas, but we would actually delete that section that deals with the individual section. I will give it to you so that you know I am not intending to mislead. Clause 33A says:

The *information in the *chip in your access card consists of 2 parts:

(a) information in your area of the chip;

And, of course, (b) goes onto the Commonwealth area. If we deleted that section, would that be problematic?

Mr Burke —ABA does not really have a position on that. Our interests at the moment are fairly narrow in respect to the bill. As I was saying a little earlier in answer to a question, there has been no ABA discussion on private space and what to do with it.

Senator STOTT DESPOJA —I think Senator Lundy pre-empted my questions in that area. Are you willing to take questions on notice? I might just write a couple down in relation to some of the fraud offences provisions and see if you have any views on them.

Mr Burke —Certainly.

Senator STOTT DESPOJA —That is helpful. Thank you.

Senator NETTLE —My first question relates to the emergency payments proposal in the access card. The government is saying that you can use this access card at an ATM to get your emergency payment when there has been a cyclone. That is all presuming, of course, that the ATMs and the electricity are working and that you have the card and it did not get washed away or whatever. I do not know what level of consultation is already going on between the government and the banks on that process. Have you been involved in a process of consultation around that?

Mr Burke —No. I understand that there is going to be some consultation. I have had advice on that from the government’s advisers. There has been no consultation with the ABA. We think that it is an idea that has some merit, as we said in our earlier submission. It emerged out of the Cyclone Larry problems. It is a good idea but we think there is still a range of issues to be sorted through from a policy and operational point of view. There has been no discussion to date.

CHAIR —On page 3 you seem a bit sceptical of its utility. On page 3 you say—

Mr Burke —Is this the submission from July last year?

CHAIR —No, it is the March submission. On page 3 you say:

The Government has indicated it sees value in the Access Card being available to assist with the payment of emergency relief.

You also say:

Whilst there is merit in such an initiative, there is also a risk of potential fraud and money laundering ...

Mr Burke —The point is that those issues will have to be worked through. They are not insurmountable. We are not sceptical about it; we are just saying that those issues have to be worked through.

CHAIR —You are not sceptical about it?

Mr Burke —I am not.

Senator NETTLE —I appreciate that the ABA has not been involved in any consultation. Are you aware of whether the bank has been doing that individually with the government?

Mr Burke —I do not believe so.

Senator NETTLE —I read through your comment on the exposure draft to the bill in which you have a recommendation that relates to the emergency payments. It is recommendation 5 in that submission and it says:

The ABA recommends that there be further information and consultation on the issue of emergency payments, noting that industry involvement will be critical in ensuring an efficient and smooth implementation of any Government proposal.

I understand what you are saying there, but would you elaborate for us on what kind of industry involvement. Are you confining that comment to the emergency payments? For example, the architect of the legislation from the Office of Access Card has been speaking at conferences, where she is purported to have said—and this was not her view—that it was about finding a way to have a cashless society and that it was also about what retail opportunities were available to private business through the access card. I am trying to work out what you want consultation and discussion to occur around. I am trying to work out whether your recommendations on the exposure draft about industry involvement in the access card relate just to the emergency payments section or whether they are broader than that?

Mr Burke —It is both, really. The emergency payments part of the submission is simply to note that there has been discussion about this emergency payment but we are yet to have consultation on the detail. That needs to happen if emergency payments are to occur.

Senator NETTLE —So do your comments relate only to emergency payments?

Mr Burke —Yes.

Senator NETTLE —The government’s submission provided to the Senate talks about what it calls an ‘emergency payment number’ that is to be recorded on the chip and in the register in order to facilitate and direct the payment of funds. The submission then goes on to say that this is not a personal account number. I have been struggling to understand how this would work. As you have said that there is no consultation going on, perhaps you cannot help me with this question. You do not put the bank account number on it but, if you are going to get the money from the ATM, presumably you have to have some connection for that person to get the money. I do not know whether this is a technical question or something you are not able to answer yet because you do not know: can you explain to me how this system could work in relation to getting money from an ATM without the government having some link between your access card and your personal bank account details?

Mr Burke —I am not sure that we can help you today because, again, there just has not been the consultation on that level of detail. I think it would be inappropriate for me to speculate on how that might work until we have had that opportunity.

Senator NETTLE —I accept what you say, that there has not been any government consultation on it, but is there any advice of a technical nature that you are able to give us in relation to this—even just whether it is possible?

Mr Bell —I know what you are saying, Senator. I think what you need to do is have a conversation with someone who is a technical expert on how banking facilities work—in other words, if you stick your card into the ATM how do you get your money out, what are the signals that go around the system that allow you to get your money out. We are not technically qualified to answer that.

Senator NETTLE —We have the department before us tomorrow, and I will pursue this matter further with them. I would like to flag now that if I am unable to get anywhere with them I might want to come back to you and ask whether you could find us that information.

Mr Bell —We would be happy to find you someone who could tell you how all the signalling works between the switches and so on.

Senator NETTLE —Yes; I just want to know whether it is possible, not necessarily for the access card but whether it is possible to do that without the government having that link.

Mr Burke —David and I could explain, and a technical expert could explain how it might work, but the crucial issue is the determination of how it should work, and that is really not for us to speculate.

Mr Bell —We could explain how the banks’ system works, but as to how any access card might interoperate with it, if that were to happen, would be in the realm of speculation.

Senator NETTLE —A lot of this bill is in the realm of speculation for us because we do not have the detail there that we are being asked to explore, and that is the playing field we are on, unfortunately. we are being asked to pass legislation without these details, and I am trying to find out information from anywhere and everywhere so that I can gain some understanding of what is being proposed. I am not trying to make you speculate, but I am being forced to speculate.

Mr Bell —Sure.

Senator NETTLE —The other question I want to ask you is about the concerns that you have raised about what you describe as inconsistencies that exist within the bill and the explanatory memorandum. I accept what you are saying about wanting to make sure that the law as it is written is clear, but my question is a broader one: is what you are asking in fact to make it easier for businesses to use the access card as an ID card?

Mr Bell —No. What we are saying is that the effect of the conflict that applies between the bill and the current AML act will make it more difficult for customers—and, incidentally, more expensive for banks. There are real issues of utility for customers if that happens. That is what we are saying.

Senator NETTLE —I understand the AML legislation and I understand the inconsistencies that you are pointing to. I can see why from your perspective you want to sort this out, because you do not want banks to be prosecuted through people giving their access card as identification. I accept what you are saying in terms of the technical detail of it. My question is a broader one: by resolving the technical detail, is your overall objective about allowing the banks to use the access card as an ID card and not be prosecuted for it? Or, perhaps if we take out the word ‘ID card’, to use the access card as a form of identification and not be prosecuted for it? Is that the big picture?

Mr Bell —If the parliament passes legislation and customers wish to offer the card as a form of identification for the 100 points checked, it will make it easier all round.

CHAIR —But, if the card does not have a photo, does not have a signature, does not have a number on it, it would not be that much use for the banks, would it?

Mr Bell —Presumably then AUSTRAC, in allocating the points to it, would reduce the number of points

CHAIR —As I mentioned, we are not here to produce a form of identity for the private sector; we are here to facilitate access to welfare. You understand that?

Mr Burke —We understand that.

Mr Bell —Yes.

Senator FORSHAW —Does the association have a view about whether or not there should be a second part of the card that can take this private information—if I can call it that—whatever it is? There are options for people to put on all sorts of things, such as medical history and so on. Do you have a view about that?

Mr Bell —I do not think we do, do we?

Mr Burke —No, we do not have a view on that at all.

Senator FORSHAW —Because that information could also presumably relate to the banking industry or financial material.

Mr Bell —That has not emerged in discussions with our members, no. We do not have a view on that.

CHAIR —There being no further questions, gentlemen, I thank you very much for your help. You have been very helpful to the committee this afternoon and we appreciate it.

[3.44 pm]