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This joint submission is made on behalf of members of the Consumers’ Federation of Australia (CFA) and other consumer representatives and advocates. It builds upon our previous submission made to review (Original Submission).

This submission responds to the specific issues raised in the review’s Interim Report and only addresses the issues and recommendations already covered in the Original Submission to the extent that it is necessary and relevant to the Interim Report.

In general, the Interim Report does a good job of summarising the relevant broad thematic issues that underpin the role of the Code. The six issues raised by the Interim Report are interrelated and speak to the role of the Code, and how it can best deliver positive outcomes for customers and banks. These issues need to be considered in light of the primary purpose of the Code, which must be to improve consumer and small business banking customer outcomes.

We support some of the potential changes floated in the Interim Report to help improve the Code’s efficacy. At a high level, our view is that the current level of detail in the Code generally is appropriate for its purpose. The Code’s current variety of broad commitments and more specific requirements provides value to customers in different ways and makes for a more useful guiding document. We also agree that the 2019 rewrite of the Code improved its accessibility for everyone who may refer to it.

While we made many recommendations in our Original Submission, we do not consider that the Code requires a complete overhaul or rewrite for it to be fit for purpose. Our recommendations are aimed at improving the content of the Code to help address more specific issues, particularly where we see evidence of consumer harm. The Code is not the appropriate vehicle to solve every problem in banking, but there are many areas where extra or improved content could help it do more.

Obviously, the Interim Report does not delve into the specific or more detailed recommended changes to the Code raised in submissions. We appreciate that settling a position on the issues raised in the Interim Report will have some impact on whether and how many of those more specific changes are adopted and implemented.

Read our full submission (PDF).