A bank should not show remitter’s address on the electronic advice issued to payee- DPP3
The Complaint
The Complainant instructed Bank A to remit a sum of money by telegraphic transfer to an account at Bank B, and later found that the electronic advice issued to the payee by Bank B showed his name and address. Dissatisfied with Bank B’s disclosure of his address to the payee on the electronic advice, the Complainant lodged a complaint with the PCPD.
Bank B explained that when it received an international telegraphic transfer from the remitting bank (i.e. Bank A), it would extract two lines of text from the field of remitter’s information and put it into the electronic advice in accordance with the banking practices so as to provide sufficient information to the payee for identification of the remitter. According to Bank B, the remitting bank generally inputs the remitter’s name in the first line of the field and the remitter’s address in the second line.
Outcome
According to the information provided by Bank B, the purpose of showing the remitter’s name and address on the electronic advice was to provide sufficient information to the payee for identification of the remitter. However, it seemed that Bank B had not considered the fact that the payee might not have known the remitter’s address (as in this case). Therefore, the act of showing the data on the electronic advice could not help the payee to identify the remitter, but the remitter’s address was unnecessarily disclosed to the payee. The Commissioner is of the view that showing the remitter’s name and account data on the electronic advice is sufficient to achieve the purpose of identifying the remitter by the payee. Hence, the act of Bank B in the case had contravened DPP3.
After the PCPD’s intervention, Bank B agreed to amend the format of its electronic advice, which would then only show the data in the first line of the field. Such amendment can avoid unnecessarily disclosing the remitter’s address to the payee in future.
(Uploaded in September 2016)