On 6 July 2020, the Banking Code Compliance Committee (BCCC) launched an Inquiry into Code-subscribing banks’ compliance with Part 4 of the Banking Code of Practice (the Code). The obligations under Part 4 of the Code are key consumer protections for disadvantaged customers and are particularly relevant as the community faces heightened challenges due to the COVID-19 pandemic.

When the Banking Code came into effect in July 2019, banks were required to comply with several new obligations, including requirements to:

  • take extra care with customers experiencing vulnerable circumstances
  • make services inclusive and accessible to everybody, including older people, people with disability, Indigenous people (including in remote locations) and people with limited English
  • provide customers with information about low or no fee accounts that might suit their needs if they tell the bank they’re on a low income, and
  • be sensitive, respectful and compassionate towards people experiencing vulnerable situations.

Banks’ compliance with the Code’s protections for customers experiencing vulnerable circumstances is a key priority for the BCCC under its Business Plan. The Inquiry was also prompted by the BCCC’s Inquiry: Banks’ transition to the 2019 Code, which found that while banks had made significant efforts to empower staff to take extra care with customers experiencing vulnerable circumstances – there was more work to be done.

The BCCC finalised the scope of the Inquiry after receiving comprehensive feedback from banks, the Australian Banking Association (ABA), the Australian Financial Complaints Authority (AFCA) and a number of consumer advocacy groups and small business stakeholders.

The BCCC plans to conduct the Inquiry over the course of the next nine months. It will cover how banks consider vulnerability, inclusivity and accessibility throughout the entire consumer and small business banking experience, including the design of products and services, lending, financial difficulty, complaint resolution and debt recovery. The BCCC will also seek to understand how banks have set up cultural, system and training frameworks to support staff to comply with the Code.

The BCCC invites individual and small business customers and their representatives to engage with us throughout the Inquiry – to share any insights, case studies, areas of concern and examples of good practice. The BCCC welcomes input from interested parties and can be contacted by email at: info@codecompliance.org.au.

Further information about the BCCC is available on its website – bankingcode.org.au.