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Banking Code Review: Interim Report

8 September 2021

The Interim Report for 2021’s Banking Code Review is now available. Drawing on the submissions and consultation meetings to date, the interim report draws out
some overarching themes and issues surrounding the review of the Code, along with some preliminary observations on these issues.

All published submissions to the code review can be found here.


Summary of Issues Raised in Interim Report

  • Influence of Royal Commission: Ensuring the momentum coming from the Royal Commission in terms of improving
    awareness and compliance with the Code is maintained.
  • Importance of the Code: Identifying measures that will encourage all banks to view the Code as important in identifying the customer focus that is central to the overall success of their organisation, rather than a regulatory burden.
  • Overlap between the Code and the law: The implications of the growing overlap between consumer protections covered in the law and the commitments in the Code, including banks responding to multiple compliance regimes.
  • The Code’s audience: Whether the one document is trying to meet the needs of too many audiences.
  • Principle-based or prescriptive drafting: Whether a more principle-based approach to drafting, with the procedural detail on the implementation of consumer commitments included in Code-related industry guidelines, would facilitate a simpler and more flexible document, help future proof the Code, and focus it more on intended consumer outcomes.
  • Fair, reasonable and ethical: Clarifying that engaging with the customer in a fair, reasonable and ethical manner is a key principle that underpins all commitments in the Code, and this should be clearly reflected in the Code, along with advising customers that this commitment is enforceable under legislation.

Download the full interim report:

View online

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