The 2010-2011 reporting period has been a very positive and successful year for the CCMC and its Secretariat, marked by key achievements in its three strategic focus areas.
MONITORING – key ACS outcomes
The key objective of the ACS program is to assist the CCMC to assess, monitor and verify that the Banks are meeting their Code obligations. In summary:
- The Banks reported 2,541 compliance breaches, an increase of 48% from 2009-2010.
- Most individual breaches in 2010-2011 related to the ‘Provision of Credit’ and ‘Privacy and Other’ categories.
- Compared to 2009-2010, the number of self reported breaches in the ‘General Commitments’ category also increased, up by 106% from 200 breaches to 412.
- There were decreases in the number of breaches reported in the following categories:
- Disclosure, down by 21% (from 122 to 96 breaches); and
- Provision of Banking Service, down 44% (from 87 to 49 breaches).
The CCMC notes that it has encouraged a culture of positive breach reporting by the Banks and accordingly the increase in breach numbers does not of itself mean an increase in non compliant behaviour across the banking sector. Nevertheless, the CCMC would expect Banks to remain vigilant about the monitoring and rectification of Code breaches in the year ahead and encourages the Banks to reduce the overall breach numbers reported in the next ACS.
A key CCMC goal is that its compliance activities influence positive changes in industry behaviour. In that context the CCMC has, and will continue to engage in projects that challenge current thinking and accepted practices, test the customer experience against Code obligations, identify areas of best practice and build awareness and acceptance of the Code. While each project is unique, the CCMC uses a broad range of techniques in this arena, including shadow shopping, focus groups, surveys, public forums and academic specialists.
The Code empowers the CCMC to investigate and determine any allegation from any person that a Bank has breached the Code. The CCMC can also conduct its own, self initiated investigations. When investigating a matter, the CCMC considers:
- whether a breach has occurred and its extent;
- the broader and potential impacts;
- the effect of non-compliance on the Bank;
- the root cause of the breach and whether it may be systemic; and
- any remedial action proposed or taken by the Bank.
A copy of the 2010-2011 Annual Report is available here.