2.1 Purpose of the consultancy
The purpose of the independent investigation into Automatic Teller Machines (ATM) and EFTPOS capabilities and transaction functionality is to:
- provide comprehensive information on current and future Automatic Teller Machine (ATM) and EFTPOS functionality; and
- to inform the development of a national harm minimisation strategy on specific initiatives available or possible to limit access to cash and credit through ATM and EFTPOS in gambling environments.
Specifically the requirements of the project were to:
- Investigate current ATM and EFTPOS functions and capabilities including:
- links and access to credit accounts, draw down facilities and other ‘credit type’ accounts;
- commercial issues for non bank owned ATMs/EFTPOS; and
- current technologies and their capabilities.
- Investigate future ATM and EFTPOS functions that could limit or change access capabilities (including access to credit) including:
- technical feasibility of changes to functions and capabilities;
- possible convergent technologies (eg Smartcard) that could be linked to financial transactions;
- technological requirements for change;
- financial institutions and other stakeholders and their role in changes to technology;
- the commercial viability of specific function ATMs;
- the commercial viability of convergent technologies; and
- timeframes for the introduction of new technologies.
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2.2 Our approach
The project was undertaken in four stages: project establishment; research and analysis; impact analysis; and reporting.
Our approach to the research consisted of two key areas of focus:
- desk based research and analysis (quantitative); and
- primary research capturing a range of methods – face-to-face interviews, group sessions, telephoneinterviews and questionnaires (qualitative).
In the desk based research and analysis we aimed to investigate the current legislative and operating framework for ATMs andEFTPOS. Key issues investigated included:
- current regulatory requirements as they relate to the gaming, gambling, and banking industries;
- current practices as they relate to the gaming and gambling industries;
- functionality of both bank and non-bank owned ATMs; and
- accessibility to credit and draw down facilities.
A list of the websites accessed and documentation researched is at Appendix B.
In the primary research and analysis we aimed to capture information and the views and perceptions of the key financial sector stakeholders. These stakeholders included:
- the 4 major banks (ANZ, Commonwealth Bank, National Australia Bank, and Westpac);
- Australian Bankers Association;
- Reserve Bank of Australia2;
- Australian Competition and Consumer Commission;
- major providers of non-bank ATMs and EFTPOS in the gaming and gambling environment; and
- major gaming and gambling providers (via the industry and sector peak bodies).
A list of the key organisations consulted is at Appendix A. The third stage of the project focused on examining the impact of any potential change on the various sectors.
The purpose of this stage was to gain a broad understanding of the issues confronting the banking and finance and gaming and gambling industries as they relate to limiting ATM/EFTPOS functionality and capability in the gaming and gambling sectors. It was envisaged that any changes or increases in regulation might have commercial implications across both industries, in particular for gambling and gaming venues and ATM/EFTPOS infrastructure providers. An impact analysis was undertaken to confirm commercial implications that may arise from the introduction of specific function ATMs and for convergent technologies.
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2.3 Key areas of investigation
The following summarises the key areas of investigation undertaken for the project within the sectors of interest.
2.3.1 Financial services sector
Key issues considered included:
- functionality and capacity of ATM/EFTPOS;
- accessibility including location, venue, services and access to cash and/or credit;
- technology – current and future technological developments;
- products – use of different financial sector products and devices (credit, debit, redraw);
- consideration of the role of various deployers;
- potential impacts of alternative propositions – commercial, customer service; and
- potential impacts on ATM and EFTPOS providers.
2.3.2 Regulatory environment
Key areas considered included:
- current regulations across jurisdictions;
- consistency of regulations between banks and non banks;
- global comparison;
- future considerations;
- any known inputs/outcomes of regulations;
- potential impacts of regulatory change; and
- capacity for regulatory change.
2.3.3 Community sector
Key areas considered included:
- impact of potential changes on the social gambler; and
- ATM/EFTPOS accessibility in gambling and gaming environments.
2.3.4 Gaming/gambling sector
Key areas considered included:
- commercial impact of any regulatory or technological change;
- impact on social gamblers; and
- impact on customer service.
The project methodology was formulated with, and approved by, the project steering committee.