Monitoring Code breaches
How the Customer Owned Banking Code Compliance Committee (COBCCC) monitors compliance
The COBCCC is an independent body that monitors adherence to the Code while also providing guidance and support to subscribers.
We work proactively with subscribers to guide compliance improvements.
We have the authority to sanction customer owned banking institutions if they do not take corrective action after breaches.
Find out more information about the COBCCC here.
The COBCCC has oversight of subscribers’ culture through its Code monitoring and investigation functions and responsibilities.
Each year, participating customer owned banking institutions complete our Annual Compliance Statement (ACS), which documents their Code compliance performance.
The ACS questionnaire is developed in collaboration with the customer owned banking sector to help subscribers effectively self-assess compliance with the Code.
We then review their responses to assess:
- how effectively they have complied with their Code obligations
- the maturity of their Code compliance monitoring frameworks
- how effectively they have monitored their compliance against Code obligations
- instances of non-compliance and how they were fixed
- emerging or significant risks to their compliance with Code obligations, and
- areas of good practice that can be shared with industry.
Results are published in the Customer Owned Banking Code Compliance Committee Annual Report and Annual Data Report which offer valuable insights into the industry’s compliance performance.
Our verification program tests and validates customer owned banking institutions’ Code compliance programs, including how effectively they identify, report and fix breaches of the Code.
We regularly review customer owned banking institutions’ compliance with Code obligations through our Own Motion Inquiries.
We report on these reviews to share our experience with the industry and encourage good practice.
It also enables us to provide learning opportunities when we have identified areas of improvement.
We initiate an inquiry when an area of emerging risk is identified in the customer owned banking industry.