In a submission paper responding to the ACA discussion paper on "Preventing Unexpected High Bills: Credit Management in the Telecommunications Industry," the AMTA said the most appropriate course of action would be to "let competition continue to address the issue of credit management".
In the discussion paper, the ACA suggested that "unambiguous warnings of expenditure, as well as set expenditure limits or bill caps be applied" to help customers control their phone bill.
However, AMTA said those services are already available in the form of prepaid plans and spend alerts.
"Such services are developed as a result of competition, with carriers offering these services to attract customers to them over the competition. A competitive marketplace will ensure that such services become more widespread and innovative," AMTA said.
AMTA added that there are also problems in imposing call caps since what suits one customer may not necessarily suit another.
"What is considered a problem for one customer may be hundreds of dollars different to a problem for another. Although when they do occur the problems may be serious, mobile-related problems appear limited as regards both their incidence and size. It seems likely that imposing a 'hard cap' would inconvenience and discriminate against the majority for the sake of a minority," AMTA said.
AMTA said that although being able to nominate a cap may help customers manage their credit, it would not necessarily prevent a customer incurring a high bill since the user can easily change their cap level.
"It is suggested that 'hard caps' might be lifted on a case-by-case basis should a customer request it. This raises the question of who takes responsibility for any problems arising either because a cap is set at a certain level, or because one is changed or lifted."
"To force all carriers to introduce any form of cap would be problematic in that there are technical and cost barriers associated with building/changing systems to provide caps. This includes complexities associated with there being a supply chain, and the complexity involved with --for example-- real-time billing. The imposition of excessive costs risks those costs being passed on to consumers, which would obviously not be welcome."
AMTA believes that information provision is very important to ensure that the customer knows the inclusions and costs of any service. AMTA also believes that financial literacy as a whole is problematic in Australia and that financial management skills should be widely taught in schools.
"Mobile phones potentially represent one of several significant expenditure items for many Australian teenagers. AMTA is therefore actively participating in the Commonwealth's Financial Literacy Task Force, and supports its proposal for a coordinated, nation-wide approach to improved financial awareness for consumers, including that all school-age Australians should receive instruction in how to manage money. Over time this should significantly help teenagers address their financial challenges."
AMTA strongly believes that not everyone is experiencing financial hardship because of unexpected high phone bills. A vast majority of the consumers still enjoy the benefits of mobile phones without running into financial difficulty, they say.
"The continued, and increasing, popularity of pre-paids, combined with numerous other initiatives to facilitate credit management, indicates that the market is responding to credit management issues," the AMTA submission paper said.
AMTA said that that any initiatives or "fixes" considered by the ACA must be proportionate to the problem.