In our joint submission with Financial Rights Legal Centre to the Report Two of the Customer Owned Banking Association’s (COBA) independent review of the Customer Owned Banking Code of Practice (COBA Code), we support a number of the recommendations made in the Review Report. We are pleased to see that a large proportion of the recommendations made by the Joint Consumer Submission have been taken up and integrated into the Review Report, initial drafting and recommendations. Many of these bring the COBA Code in line with the commitments made by the Australian Banking Association (ABA) Code and would help address issues of fairness for banking customers.
However, some of the recommendations and drafting in relation to financial vulnerability do not meet the current commitments of the ABA, keeping COBA behind the ABA Code. These include recommendations regarding commitments to Aboriginal and Torres Strait Islanders, basic bank accounts, financial difficulty, property insurance and proactive data analysis. We question the reasoning behind these decisions and request that the Review team consider its position.