Our monitoring program

We initiate inquiries into compliance issues of particular concern. Major inquiries – such as our  inquiry into banks’ transition to the 2019 Code – generally examine all banks’ compliance with a broad obligation, often in an exploratory way. At the end of any major inquiry we publish a report sharing experience and identifying areas of good practice.

We also conduct smaller, targeted inquiries, examining a single bank, a subset of banks or a industry-wide but very specific issue. After completing a targeted inquiry, we may issue a finding, recommendation and/or publication.

We encourage banks to have a positive culture of self-reporting, taking responsibility for identifying breaches, reporting them and making practice improvements to prevent future breaches. Every six months, banks must self-report breaches of the Code by completing a Banking Code Compliance Statement. We use this data to identify problems and advise banks on where they can improve, and publish the results in our Compliance Statement reports.

The Committee has powers to investigate alleged breaches of the Code as well as potential breaches we identify through our monitoring activities, such as inquiries. Our investigations examine whether a bank has complied with its Code obligations and if it needs to change its policies or processes. Investigations give the Committee an opportunity to focus on concerns raised by individual customers, and to consider compliance issues within individual banks.

When the Committee concludes an investigation it will issue a Finding on whether a bank has breached the Code. The Committee publishes its Findings on a de-identified basis and may also include good practice guidance for all banks to consider.

We focus on the important issues, particularly ones that are industry-wide, serious or systemic, to make the best use of our resources for the greatest impact.

Our Priority Monitoring Framework (PMF) supports us to manage our priorities and focus our work so we can help Code subscribers comply with their obligations.

The PMF sets out the four key elements of our priority monitoring cycle.

It explains the interconnected and complementary activities we undertake to monitor compliance, encourage best practice and identify priority focus areas.