Monitoring Compliance with the Code of Banking Practice - 2017-18 YEAR IN REVIEW

Monitoring Compliance with the Code of Banking Practice - 2017-18 YEAR IN REVIEW
Compliance with
the Code of Banking

                         2017–18 YEAR IN REVIEW   1
Monitoring Compliance with the Code of Banking Practice - 2017-18 YEAR IN REVIEW
Message from the Chair and CEO                         3     The Committee                                  12

Annual Compliance Statement                            4     The secretariat                                13

Direct debits                                          6     CCMC financials                                14

Breach reporting                                       7     Appendix 1 – Investigation summary             14

Investigations                                         8     About the CCMC                                 15

Working with stakeholders and the
community                                              11

Year in review

—— 10,123 Code breaches in 2017–18, a 9.5%                    —— presented to the Annual Credit Law
   decrease from 11,191 breaches in 2016–17                      Conference, National Elder Abuse
—— 3.43 million customers impacted – at                          Conference and Financial Counselling
   least $95 million financial impact                            Australia Conference
—— banks told us 93% of breaches are                          —— provided training to Financial
   caused by human error                                         Ombudsman Service staff and financial
                                                                 counsellors in South Australia, Victoria
—— corrective actions taken in only 39%
                                                                 and Tasmania
   of breaches, to address customers
   individual issues                                          —— held more than 100 meetings with

INVESTIGATIONS                           DIRECT DEBITS                         BREACH REPORTING
—— prompted improvement in               —— improved information               INQUIRY
   banks’ practices through                 available for customers on         —— increased transparency
   compliance investigations                banks’ websites                       in banks’ compliance with
                                         —— improving compliance                  the Code
                                            with the Code’s direct             —— developed new insights to
                                            debit obligations in some             support targeted inquiries
                                            banks                                 and investigations
                                         —— planned ongoing                    —— shared learnings to
                                            monitoring to encourage               promote better outcomes
                                            continued improvement                 for customers

Monitoring Compliance with the Code of Banking Practice - 2017-18 YEAR IN REVIEW
Message from the Chair and CEO
                                                                            go unnoticed. The CCMC also set
                                                                            the expectation that banks should
                                                                            assess customer impact for all
                                                                            breaches. Breaches that affect
                                                                            customers must be corrected and
                                                                            where appropriate, the customer
                                                                            should be compensated.
                                                                            As the CCMC prepares for the
                                                                            new year, we remain focused
                                                                            on providing robust monitoring
                                                                            and leading a smooth transition
                                                                            to the new Code. As set out in
                                                                            our Strategic Plan, we intend to
                                                                            develop guidance for banks to
                                                                            encourage a consistent approach
                                                                            and ensure that they are ready to
                                                                            comply with the new Code from 1
                                                                            July 2019.

This year brought more change         However, this year we decided         As always, I thank my colleagues
and challenges for the banking        to present only a summary of          Gordon Renouf and Sharon
sector and the CCMC. In 2017–18       the data, setting out banks’ full     Projekt for their support and
we faced a formidable workload        end-of-year results in a separate,    expertise during the year. Sharon’s
as preparations for the new           dedicated report released in          term on the Committee came
Banking Code of Practice hit          November 2018.                        to an end on 26 October 2018
full swing and we were invited                                              and we take this opportunity to
                                      Due to ongoing and systemic           express our thanks to Sharon for
to contribute to the Royal
                                      noncompliance, the cancellation       her invaluable contribution to
Commission into Misconduct in
                                      of direct debits has been a           the CCMC where she fulfilled the
the Banking, Superannuation and
                                      consistent focus of our monitoring    role of Industry Representative for
Financial Services Industry.
                                      program over a number of years.       over 6 years. Anne O’Donnell has
Despite these additional              We are determined to oversee          been recently appointed by the
demands on our time, we kept          major improvement to banks’           Australian Banking Association as
a strong business-as-usual            direct debit practices, and while     the new Industry Representative
focus. Maintaining a robust           our renewed focus on direct           for a three-year term. Welcome to
compliance monitoring program         debits prompted some progress         the CCMC Anne, we look forward
is the CCMC’s top priority. To        this year, banks still have a long    to working with you in the years
that end, this year we devoted        way to go. The CCMC will keep         to come.
substantial time to improving         the pressure on banks to do
our ways of working, improving        better on direct debits, and will     Finally, the Committee also thank
our data collection strategy and      be reporting on the results of a      our secretariat staff led by Chief
building on our Code compliance       new large-scale mystery shopping      Executive, Sally Davis, who has
risk framework to inform our          activity in the first half of 2019.   once again provided us with
investigations and inquiries. We’ve                                         expert guidance and support over
                                      Another focus for 2017–18 was         the last 12 months.
also prioritised recruitment to
                                      improving the quality and
bring in new compliance analysts
                                      consistency in the way banks
to bolster our work capacity and
                                      identify, record and report Code
                                      breaches. Reporting on our
Through our Annual Compliance         breach reporting inquiry in June
                                                                            Christopher Doogan AM
Statement we’ve implemented           2018, we presented a clearer
our new data collection strategy      picture of banks’ Code breaches
and have been able to examine         and identified a way forward
a comprehensive data set              for their monitoring processes.
that better articulates banks’        We expect banks to have robust
compliance with the Code. In the      compliance frameworks that            Sally Davis
past we have detailed ACS results     review staff, processes and
in the CCMC’s annual report.          systems to ensure errors do not

                                                                                          2017–18 YEAR IN REVIEW   3
Monitoring Compliance with the Code of Banking Practice - 2017-18 YEAR IN REVIEW

                                                               10,123 breaches
                                                                9.5% since 2016–17
                                                               at least

                                                               3.43 million
                                                               people impacted

                                                               at least

             Annual                                            $95 million
                                                               financial impact

             The Annual Compliance                           TH E R ESU LTS: CO D E
             Statement (ACS) was once                        CO M PLI A N C E I N 201 7 –1 8
             again the centrepiece of our                    This year, banks self-reported 10,123
             monitoring efforts, providing                   breaches of the Code, a decrease of
             a big-picture overview of how                   approximately 9.5% from 11,191 in 2016–17.
                                                             The main categories for self-reported
             well banks are complying with                   breaches – [provision of credit, privacy and
             their Code obligations.                         confidentiality, and debt collection] – have
                                                             remained largely unchanged for the last
             Data received through the ACS is used by        three years.
             the CCMC to identify emerging risks, set
             its priorities for inquiries and in-depth-
             investigations, and advise banks on where
             they can improve.

             A full summary of the CCMC’s analysis of bank’s ACS responses can be
             found in the Data Report.

Monitoring Compliance with the Code of Banking Practice - 2017-18 YEAR IN REVIEW
COMPL AINTS                                                    F I N A N C I A L D I F F I C U LT Y

complaints received
                                                                  applications for assistance

 6%              since 2016–17                                    1.6%                    since

91% closed within
    5 days
                                                                  applications approved

6%              closed between
                6 – 21 days
                                                                  69.5%                   of all applications

3%              closed after                                       3%                since
                21 days

        T O P 5 B R E A C H C AT E G O R I E S F O R 2 0 1 7 – 1 8

                Privacy and            Provision of           Debt                  Compliance                Dispute
                Confidentiality        Credit                 Collection            with Laws                 Resolution

 Breaches       4,464                  2,489                 725                    594                       406
 Impacted       465,166                12,649                18,214                 733,148                   1,203
 Impact         $678,656               $8,436,790            $141,550               $9,434,113                $39,300

See the CCMC’s Code Breach Data Report 2017–18 for more detail on banks’ self-reported breaches in 2017–18.

                                                                                                          2017–18 YEAR IN REVIEW   5
Direct debits
The Code gives customers the right to cancel a direct debit with their
bank. But while our continued focus on direct debit practices prompted
some improvement this year, banks still have a long way to go.


In early 2017, the CCMC conducted mystery              —— improve the direct debit information on
shopping in response to mounting customer                 their websites
concerns that banks were not complying with            —— enable customers to cancel direct debits
their direct debit obligations. This revealed             themselves with online banking
ongoing and systemic non-compliance: bank
                                                       —— provide direct debits training to more staff,
staff provided compliant advice in only 46% of
                                                          more often
                                                       —— measure compliance with internal mystery
Reporting on these results, we sent a clear               shopping
message that ongoing non-compliance
                                                       —— make sure compliance and quality
was unacceptable. We challenged banks to
                                                          assurance staff identify and manage
improve their practices, recommending
                                                          breaches, and
that they:
                                                       —— develop ways for customers to cancel both
                                                          direct debits and recurring card payments.

MY STERY SH OPPING IN 20 18                                    M A R C H 2 0 1 8 R E S U LT S
Follow-up mystery shopping this year showed
some compliance improvement.                            Call centre compliance:
Direct debits compliance trend, 2008 to 2018
                                                        75%          (up 23%
                                                                     from 2017)

                                             56%        Branch compliance:

                                                        45%            (up 20%
                                                                       from 2017)

            36%                                         4 banks
                                                        updated information for
                                                        customers on their websites

                                                       LOO K I N G A H EA D
                                                       Industry has a long way to go to comply with
                                                       its direct debit obligations. In 2018–19, we will
                                                       conduct another large-scale mystery shopping
                                                       exercise, and banks will have to report on
2008       2010        2011       2017       2018
                                                       what they have done to implement our 2017
PERCENTAGE OF CONTACTS THAT RESULTED IN                recommendations. We will report on our
COMPLAINT RESPONSES                                    findings in the first half of 2019.

Breach reporting
This year the CCMC conducted an                                        B R EAC H R EPO R TI N G I N Q U I RY
in-depth review of banks’ breach                                       FI N D I N G S
identification, management and
                                                                       Breach numbers
reporting processes. This renewed
focus on banks’ breach reporting has                                   Code breaches reported in the 2016–17 Annual Report
                                                                       were revised upwards by almost 8% to 11,191
increased transparency, holding banks
to account for non-compliance.                                         Breach causes
                                                                       Banks reported that:
                                                                       —— 98% of breaches were caused by human error
                                                                       —— 75% of breaches had a secondary cause, most
             THE FOUR PILL ARS OF                                         commonly a process deficiency or a process not
             C C M C D ATA C O L L E C T I O N                            being followed
                                                                       —— 1% due to a system error

    1       What was the root cause?                                   ——

The CCMC has powers to investigate allegations that a bank has breached
the Code. Investigations allow us to focus on concerns raised by individual
customers, and to consider compliance issues within individual banks.
In 2017–18, the CCMC received 32 new matters containing 53 Code
breach allegations.

Alleged Code breaches                                  The CCMC closed 35 matters during 2017–18.
                                                       Of those only 10 fell within our jurisdiction and
in 2017–18
                                                       could be investigated. Of these:
                               CODE       ALLEGED      —— 5 matters were used to inform the direct
                     O B L I G AT I O N   BRE ACHES       debits inquiry, which identified systemic
                                                          non-compliance and a need for ongoing
    Key commitments – Act fairly
               and reasonably             11              monitoring.
                                                       —— 2 matters resulted in three confirmed
                Financial difficulty      8               breaches of financial difficulty, debt
                                                          collection and internal dispute resolution
                                                          obligations. The banks involved
       Internal dispute resolution        7               acknowledged the breaches and
                                                          demonstrated to the CCMC that they had
                Provision of credit       6               remediated the customers affected and
                                                          changed their processes to prevent future
            Compliance with laws          5            —— 3 matters were investigated with the CCMC
                                                          finding that no breach had occurred.
            Copies of documents           4
                                                       Matters that we could not investigate:
                     Chargebacks          4                Withdrawn/no further contact                   13

                   Debt collection        2                Not a Code-subscriber/product not
                                                           covered by the Code

       Privacy and confidentiality        2                Unable to investige (clause 3 and/
                                                           or 42)

                     Direct debits        1                Adopt finding of another forum                 1

            Terms and conditions          1
           Statements of account          1
                                                        Code clause 36(b)iii states that the CCMC’s
    Information relating to foreign
               exchange services          1            compliance monitoring functions and powers do
                                                       not extend to clauses 3 and 4 of the Code unless

                                                       a breach of clause 3 or 4 is also a breach of
                                                       another provision of the Code.

Case study: thousands of customers                        Don’t set and forget – all communications
                                                          require regular review for compliance
were sent incorrect information about
financial difficulty arrangements – in                    The CCMC is very concerned that this letter
                                                          remained in circulation for such a long
breach of Code clause 32.1                                period, without being identified by the
In November 2016, a community legal centre                bank’s compliance or legal teams. The bank’s
approached the CCMC with concerns about how               oversight – both in approving the letter and
one bank was communicating with its customers             allowing it to remain in circulation for so
about financial difficulty arrangements.                  long – demonstrates a breakdown in the
                                                          bank’s financial difficulty and debt collection
The community legal centre told the CCMC that             compliance framework.
the bank was writing to customers, advising them
that they had been approved for financial difficulty
assistance and would not receive further collections
                                                              The CCMC puts
calls. However, the bank also advised customers
that it may issue default or other legal notices, close
                                                              banks on notice
the account or default list the customer.                     that all customer
The CCMC’s investigation found that for three
years, the bank had been issuing this letter to all
customers with an approved financial difficulty               must be regularly
arrangement. Over this time, the bank estimated,
about 75,000 customers had received the letter.               reviewed against legal,
The bank acknowledged the breach of Code clause               regulatory and Code
32.1 and removed the letter from circulation.

                                                                                            2017–18 YEAR IN REVIEW   9
or language difficulties. The Code          and financial counsellors to foster
                                            requires banks to have processes            better working relationships.
                                            to swiftly accept and act on those          The CCMC understands that the
                                            authorities and instructions.               bank now assigns represented
                                                                                        customers to specialist staff for
                                            In late 2016 a community                    assistance.
                                            legal centre employee raised
                                            concerns that a bank was not
                                            acting on her letter of authority.
                                                                                              If an authority
                                            The representative told the
                                            CCMC that she had advised
                                                                                              is in any way
                                            the bank that the customer                        ambiguous
                                            was particularly vulnerable and
                                            unable to manage her financial                    bank staff
                                            affairs. After providing a standard
                                            form authority to the bank, the                   should make
                                            customer continued to receive
                                            phone calls and text messages.
                                            Through its investigation, the                    enquiries,
                                            CCMC found that the breach had
                                            been caused by human error. The                   rather than
Case study: a bank failed
                                            letter of authority had not been
                                            loaded to the system correctly,
                                                                                              rely on
to act on a customer’s letter               and the bank failed to follow-up                  assumptions.
                                            and understand the nature and
of authority, and continued                 extent of the authority.
pursuing her for debt – in                                                              The CCMC expects banks to build
                                            The bank acknowledged that it               strong working relationships
breach of Code clause 32.1                  had breached the Code, and said             with not-for-profit community
                                            that it had remediated the breach           lawyers and financial counsellors,
Customers have the right
                                            by providing refresher training on          helping customers to overcome
to appoint a third-party
                                            letters of authority to all financial       their financial difficulty by
                                            difficulty and debt collection              communicating and working
A customer may wish to appoint              staff. The bank advised that it had         flexibly with their representatives.
a third-party representative for a          also improved its engagement
range of reasons, such as illness           with community legal centres

Referrer’s location, matters received in 2017–18                       LOO K I N G A H EA D
                                                                       In last year’s Annual Report, we highlighted
                                                    1 overseas         challenges in the investigations process and
                                                    1 unknown          flagged our intention to revise the approach to
                                       9                               compliance investigations. While this remains
                     3                                                 a priority, implementation has been set back
                                  3                                    due to the delay in the approval of 2019
                                            5                          Banking Code of Practice and the associated
                                      7         1                      Committee Charter.
                                                                       At the time this Report is printed, both the
                                                                       Code and Charter have now been settled and
Referral source, matters received in 2017–18                           approved, and the CCMC are actively working
                                                                       toward its revised investigations process.
 REFERRAL SOURCE                                    NUMBER

 Direct (individual customer)                          28
 Direct (small business customer)                       1
 Consumer advocate                                      2
 The Financial Ombudsman Service (FOS)  3
                                                        1               3
                                                                         The Financial Ombudsman Service (FOS) was replaced by
                                                                        the Australian Financial Complaints Authority (AFCA) on 1
 Australian Banking Association                         0               November 2018.

Working with stakeholders
and the community

This year, the CCMC continued to build strong relationships with community
and consumer organisations, whose work on the front line provides invaluable
assistance to customers.

WO R KIN G W ITH CONS UME R                            The CCMC was also pleased to present at the
                                                       Annual Credit Law Conference, National Elder
A DVOCATES A ND                                        Abuse Conference and 2018 Financial Counselling
R E P R ESEN TATIVE S                                  Australia Conference.

Part of the CCMC’s role is to educate and provide      The CCMC thanks the organisations that reported
guidance to consumer advocates and representatives     potential non-compliance and contributed to
about the Code’s benefits and its relevance to their   CCMC’s investigations and inquiries this year.
work. During 2017–18, the CCMC held Code training      Drawing on this input, the CCMC was able to
sessions with financial counsellors in Victoria,       target and improve direct debits compliance and
Tasmania and South Australia; covering key Code        begin a wide-ranging inquiry into how banks assist
protections and how to refer potential breaches to     customers in financial difficulty.
the CCMC.

                                                       WO R K I N G WI TH I N D U STRY A N D
              Presented at                             PR EPA R I N G FO R A N EW CO D E
              —— Annual Credit Law Conference
                                                       The CCMC was pleased to increase its engagement
              —— National Elder Abuse                  with industry this year. Preparing for the 2019
                 Conference                            Banking Code of Practice was a focus, and we met
              —— Financial Counselling Australia       regularly with the Australian Banking Association and
                 Conference                            ASIC on its development. Our priority was to put in
                                                       place a strong governance framework that empowers
              Provided training to                     the new Banking Code Compliance Committee to
              —— Financial counsellors in              robustly monitor compliance, share and encourage
                 Victoria, Tasmania and South          good practice and hold banks to account when
                 Australia                             things go wrong. We also engaged with banks who
                                                       are planning to subscribe to the new Code, and were
              —— FOS staff                             encouraged by some banks’ proactive approach.

              Held more than 100 meetings,             This year the CCMC made significant changes to
              including with                           our operations, data collection and inquiries. We
                                                       acknowledge Code subscribers’ cooperation and their
              —— FOS
                                                       contributions to this work.
              —— Australian Securities and
                 Investments Commission
              —— Australian Banking Association
              —— Code-subscribing and non-
                 subscribing banks
              —— Financial Counselling Groups
              —— Consumer Advocacy Groups

                                                                                     2017–18 YEAR IN REVIEW   11
The Committee
Three representatives make up the Committee. The CCMC’s Independent Chair
is jointly appointed by the ABA and the Australian Financial Complaints Authority
(AFCA) Chief Ombudsman. The Chair is joined by an Industry Representative,
appointed by Code-subscribing banks, and a Representative of Individual and
Small Business customers, appointed by the consumer representatives of the
AFCA Board of Directors.

Christopher Doogan AM                                              Sharon Projekt
FIML FAICD, Independent Chairperson                                Industry Representative

Current term: 31 January 2017 – 30 January 2020                    Current term: 7 August 2015 – 26 October 2018
Chris is a company director and lawyer by background, having       Sharon has a legal background with broad
occupied several senior positions in both the private and          experience across the Australian retail banking
public sectors.                                                    sector in the areas of legal advice, compliance,
                                                                   and internal and external dispute resolution.
His public sector positions included Deputy Comptroller-
                                                                   She was first appointed to the CCMC in August
General and Comptroller-General of Customs prior to his
appointment to the High Court of Australia as inaugural Chief
Executive and Principal Registrar. In addition to partnership in   She has extensive experience in escalated
a leading law firm of which he was the Managing Partner, he        and complex complaint handling and
has been CEO of the National Capital Authority; Chairman of a      investigations, having worked on a number of
company owned by the Commonwealth of Australia and the             high-profile projects.
State of New South Wales, Law Courts Limited; Chairman of
                                                                   Sharon has also worked on compliance-
a health insurance company, Australian Health Management
                                                                   related projects including coordinating and
Group Limited; and Chairman of Community CPS Australia
                                                                   implementing a terms and conditions project
Limited, a mutual bank (trading as Beyond Bank Australia).
                                                                   to ensure banking compliance following the
He has written an administrative law textbook, is a trained        introduction of the Financial Services Reform
mediator from Harvard Law School and has filled many               Act, Code of Banking Practice and anti-money
community positions including Vice President of the Australian     laundering legislation.
Institute of Management and membership of advisory bodies
                                                                   Sharon has worked in debt recovery, providing
relating to tertiary education, health and finance.
                                                                   legal advice on insolvency issues related to
He has been a member of several regulatory agencies                mortgage and small to medium business
including the Commonwealth Tax Practitioners Board and             banking customers. She completed the
the ACT Legal Practitioners Admission Board, and was a             Insolvency Practitioners Association of Australia
member of the Australian Business Foundation Board, the            Advanced Insolvency Law and Practice course
Principal Member of a specialist Commonwealth Appeals              in 2002.
Panel, the independent Chairman of the Audit and Risk
Committee for the Family Court of Australia and the Federal
Circuit Court of Australia; and Chairman of the Board of
the Centre for Customs and Excise Studies. He is currently
the independent member of the ACT Community Services
Directorate Audit and Risk Committee, an Adjunct Professor
at Charles Sturt University, a Director of ACT & Southern NSW
Rugby Union Limited (the Brumbies) and a member of The
Winston Churchill Memorial Trust fellowship selection panel.

The secretariat
                                                   The Committee is supported by
                                                   a secretariat through a business
                                                   arrangement with the AFCA.
                                                   The secretariat is led by Chief Executive Officer, Sally
                                                   Davis, and is supported by a team made up of a Code
                                                   Compliance Manager, an Investigations Manager and
                                                   Compliance Analysts.

Gordon Renouf                                      Sally Davis
Consumer and Small Business                        GAICD, Chief Executive Officer
                                                   September 2015 – current
Current term: 1 July 2017 – 30 June 2020
                                                   Sally was appointed as Chief Executive Officer
Gordon is a lawyer and consumer advocate. He       on 1 September 2015. Sally previously worked
is a co-founder and CEO of Ethical Consumers       as Senior Manager of Systemic Issues at FOS
Australia, which operates the Good On You          and has worked at FOS and its predecessor
ethical shopping service. He is Deputy Chair       schemes for over 18 years. Sally is an accredited
of Justice Connect and the Consumers’              mediator and holds a Bachelor of Commerce
Federation of Australia and serves on the          and a Bachelor of Laws degree from the
boards of the Telecommunications Industry          University of Melbourne and a Graduate
Ombudsman (as a Director with Consumer             Diploma (Arts) from Monash University.
Experience) and Good Environmental Choice
                                                   Sally brings to this position extensive
Australia. He served two terms as a member of
                                                   experience in financial services, as well as good
the Commonwealth Government’s Consumer
                                                   relationships with regulators, industry and
Affairs Advisory Council, and from 2007 to
                                                   consumer groups.
2009 he was a member of the executive of
Consumers International, the global peak body      Sally is also General Manager of Code
for national consumer organisations.               Compliance and Monitoring at the AFCA. Her
                                                   work as General Manager involves the oversight
Gordon has worked as Director, Policy and
                                                   of four other codes of practice in the financial
Campaigns for the consumer group CHOICE,
                                                   services industry in addition to the Code of
Director of the National Pro Bono Resource
                                                   Banking Practice.
Centre, Director of the North Australian
Aboriginal Legal Aid Service and Director of the
Northern Territory Government’s 2004 Alcohol
Framework Inquiry.

The Committee met
11 times in 2017–18

                                                                                     2017–18 YEAR IN REVIEW   13
CCMC financials                                                 Appendix 1
                                                                – Investigation summary

                                                                No determinations were made during the
                              30 JUNE          30 JUNE
                                2017             2018           2017–18 period.
 Salaries                                                        CASES                              2016 –17           2017–18
 Salaries, gross                                                 Number of cases open
 including                                                       at beginning of year                      19                 23
 Committee                                                       (1 July)
                              $656,815         $697,451
 remuneration, leave
 provisions, Super                                               Number of new cases                      49                  32
 and Payroll Tax
                                                                 Number of cases closed                   45                  35

 Expenses                                                        Number of cases open
                                                                                                           23                 20
                                                                 at end of year (30 June)
 Office Costs                   $8,943          $10,575
                                                                                                      (including 12     (including 8 on
 Professional                                                                                            on hold*)           hold*)
                               $82,659         $19,950
                                                                 BRE ACHE S                         2016 –17           2017–18
                                                                 Number of alleged Code
 and Stakeholder               $79,742         $108,594                                                    77                 53
                                                                 Number of Code breaches
 Technology                    $14,324          $8,998                                                     4                   3
 Occupancy Costs               $28,424          $51,511
                                                                 CLOSED C A SES                     2016 –17           2017–18
                                                                 Number of cases closed by
                                                                                                            1                  3
 Total Salaries and
 Expenses                     $870,907        $897,079           Number of cases closed by
                                                                                                           16                  2
                                                                 delegated decision
 Total Funding                $944,069        $1,120,919
 Annual Surplus/
                               $73,162        $223,840*
                                                                * Where an allegation is being considered by another forum, such as
                                                                AFCA or a court, the investigation is placed on hold until that other forum
                                                                has finished its review.
* Noting that the new Banking Code of Practice was
approved later than expected, the CCMC’s expenses for the
2017–18 period were less than anticipated. The CCMC has
therefore committed to contribute a portion of the surplus to
the 2018–19 budget.

About the CCMC

The CCMC is an independent compliance         CONTACTI N G TH E CCM C
monitoring body established under clause 36
of the 2013 Code of Banking Practice.         Do you want to:
Its purpose is to monitor and drive best      —— report a concern that a bank has
practice Code compliance, through a              breached the Code?
collaborative approach with the banking       —— make a general enquiry?
sector and other key stakeholders.            —— provide feedback?
To do this the CCMC will:                     —— make a media enquiry?
—— examine banks’ practices                   You can contact the CCMC using the
—— identify current and emerging industry     contact details below.
   wide problems
—— recommend improvements to bank
   practices, and
                                              BANK I N G CO D E
—— consult with and keep stakeholders and     COM PLI A N C E M O N I TO R I N G
   the public informed.
                                              COM M I TTEE
Do you want to know more about                m.   PO Box 14240 Melbourne VIC 8001
the Code or the CCMC?                         e.

If you would like to know more about the      p.   1800 931 678 (please ask for ‘Code
Code of Banking Practice or the CCMC, you          Compliance’)
can refer to the CCMC website

                                                                                    2017–18 YEAR IN REVIEW   15
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