The one question I'm asked more than any other is this: "may a broker rely solely on a contact form instead of explicit phone/email details?" The short answer: No. The long answer: The statutory language requires "contact details". ASIC guidance treats website disclosure information and FSG content practically - the disclosure must be clear and effective and sufficient for a consumer to contact the provider (INFO 291). A contact form may form *part* of contact details, but to meet the statutory objective the website disclosure must enable consumers to contact the licensee readily; relying only on an obscure form, or one that does not provide a reliable route to contact, is inconsistent with the legislative requirement and ASIC's guidance. In practice, ASIC guidance and industry practice expect direct, readily visible contact methods (telephone and/or direct email) plus a clear complaints/EDR contact.
Most generic contact forms are not compliant, and it's why we encrypt transport and integrate with Microsoft 365. It's not policied, but it should be.
Basic and Calendar contact forms are pictured. They're excellent.
A few sources:
National Consumer Credit Protection Act 2009 (Cth) - s113 (Credit guide of credit assistance providers); s126 (credit guide of credit providers).
National Consumer Credit Protection Regulations 2010 - regulations prescribing particulars/form of credit guides and related obligations.
Corporations Act 2001 (Cth) - s942B (Contents of Financial Services Guide) and s941F / Division 2A (website disclosure information).
Australian Consumer Law (Schedule 2, Competition and Consumer Act 2010) " s18 (misleading or deceptive conduct).
ASIC guidance: INFO 146 (Responsible lending / credit disclosure) and INFO 291 (FSGs and website disclosure information).
