The Banking Code Compliance Committee’s (BCCC) administration and enforcement of the Banking Code of Practice (the Code) is a key aspect of regulatory oversight in the banking sector.
The BCCC’s monitoring and enforcement activities have helped improve consumer experiences in recent years. However, we still regularly see consumer harm caused as a result of non-compliance with the Code by Australian Banking Association member banks.
We encourage the BCCC to consider the key issues raised in the joint consumer group submission to the 2021 independent review of the Code (Code Review Submission) in selecting its compliance priorities. The issues discussed in that submission are based on the forms of consumer harm involving banks most commonly seen by consumer representatives across Australia.
We have provided some further brief comments below on matters (some raised in the Code Review Submission, some not) we consider to be particularly important, based on the casework of our financial counselling and legal advice services.
More broadly, the BCCC should also continue to pressure banks to invest in improving the systems they have in place for service delivery and Code compliance. Harmful Code breaches continue to occur in ways that should not be possible. Often, when we raise these complaints with banks, we are told it was an ‘administrative error, some of which are simply unavoidable’. We disagree – the onus is on banks to ensure their systems are compliant, including if that means investing in more capable technology to meet their obligations with fewer errors.
Read the full submission (PDF).220207_BCCC_Prioritiesconsult