We support a number of the recommendations made in the Review Report and 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 ABA Code.
Some recommendations would move the COBA Code beyond the ABA Code – these are important recommendations and we would commend COBA to take these up.
However some of the recommendations and drafting do not meet the current commitments of the ABA and keep 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 also note that the Review Report has failed to address some specific concerns that we raised in our initial submission Joint Consumer Submission
