The Customer Owned Banking Code Compliance Committee

The Customer Owned Banking Code Compliance Committee (the COBCCC) is an independent body that monitors compliance with the Customer Owned Banking Code of Practice (the Code).

Our purpose is to ensure consistent and high-quality service standards are maintained for the benefit of customers.

The COBCCC's function

The COBCCC supports customer owned banking institutions to achieve good practice in the service and experience they offer their customers, independently monitor compliance and provide guidance to stakeholders about the Code.

We share information about our functions and activities as well as any investigations or inquiries we are conducting.

We work with the Customer Owned Banking Association (COBA), the Australian Financial Complaints Authority (AFCA) and Code subscribers to carry out the functions of our role.

The COBCCC’s functions and powers are set out in the Code and the Charter.

They include:

  • monitoring compliance with the Code to determine if there is a breach of the Code
  • investigating alleged breaches of the Code
  • engaging in the other functions set out in the Charter, including the preparation of reports such as the Annual Report.

The COBCCC’s role is to monitor compliance and investigate breaches of the Code. The COBCCC has the authority to sanction customer owned banking institutions if they do not take corrective action after breaches.

It conducts robust monitoring, so customers know that subscribers will be held to account for breaches and meet customer and community needs and expectations.

We monitor compliance with the Customer Owned Banking Code of Practice (the Code) and share good practice.

The Code is essentially a set of promises outlining how Australia’s customer owned banking institutions should behave in their dealings with customers.

We investigate allegations that a customer owned banking institution has breached its obligations under the Code.

If a breach has occurred, we work with the customer owned banking institution to ensure the breach does not happen again.

We engage with stakeholders to analyse the external financial services environment, share our experience of Code compliance and influence positive changes in industry. This work includes:

  • empowering customers to access their rights under the Code
  • supporting Code subscribers to comply with the Code, and
  • providing Code guidance.

We ensure efficient and effective operations.

About the Code


What the Committee does

The COBCCC undertakes a wide range of activities to effectively administer and enforce the Code.

The Code empowers the COBCCC to investigate any concern alleging a customer owned banking institution has breached the Code.

The COBCCC may also initiate its own investigations if an issue has been identified through compliance monitoring or AFCA determinations.

These investigations aim to identify:

  • the cause of alleged Code breaches
  • whether the Code breach concern indicates broader compliance issues with the Code subscriber or across the industry in general
  • the effectiveness of Code subscribers’ remedial actions to minimise the impact of breaches on customers.

The Annual Compliance Statement (ACS) is a self-assessment tool that helps subscribers review their compliance with the Code obligations every year.

It reflects on services and products provided to customers and the customer owned banking institution’s own professionalism.

It is designed to validate the Code subscriber’s compliance programs, focusing on how effectively they identify, report and remedy breaches of the Code.

Results from the ACS help the COBCCC to benchmark the industry and various segmentations within the subscriber group.

We can also undertake our own inquiries, which we call Own Motion Inquiries. These types of investigations do not depend on a specific allegation.

The COBCCC publishes annual reports that detail the previous year’s activities, outcomes of compliance monitoring and the focus of future operations.

You can read the reports here.

The Committee’s Priority Monitoring Framework (PMF) helps us manage our priorities and focus our work so we can help Code subscribers comply with their obligations to the Code and improve customer outcomes.

Its four elements enable us to:

  • monitor compliance with the Code
  • encourage best-practice compliance among subscribers, and
  • identify priority focus areas.

It ensures we use our resources effectively and conduct crucial aspects of our work with rigor and consistency.