The main goal of the ABA through the review of the Banking Code has been to reduce the reporting obligations on, and oversight of, member banks. This is a bad outcome for consumers. This joint submission responds to Consultation Paper 373 (CP373) with primary focus on the key changes to the Code amounting to reductions in consumer protections that we are most concerned about, particularly: the removal of the commitment in the current code to the clause 49 diligent and prudent banker obligation in regard to general consumer lending. We are concerned this will lead to a significant loss in practical oversight of a key area of banking (and in an area where breaches of the current Code are common); and the removal of the clauses referring to the complaint and IDR processes. We are concerned that not all of these processes are contained in law or regulatory guidance, and their removal significantly reduces the value of the Code as a public facing document.
