All four big banks must respond to a litany of proposed findings of amoral conduct in connection with their financial advice businesses, outlined by counsel assisting Rowena Orr on Friday at the royal commission on misconduct in banking.The allegations levelled at Commonwealth Bank, over a "fees for no service" case study, are a taster of the wider and compromising material that will be surveyed this week in the report of APRA's prudential panel into the bank.Orr said that "It is open to the commissioner to find that the conduct of the CBA advice licensees, CFPL, BW Financial Advice and Count might amount to misconduct."In particular, it is open to … find that each of these entities may have contravened their statutory obligation to do all things necessary to ensure the financial services covered by their licence are provided efficiently, honestly and fairly," Orr said. "Each of these also have contravened their obligation under the Corporations Act to have available adequate resources, including technological resources to provide the financial services covered by the licence and to carry out supervisory arrangements," she said. "These entities may also have contravened their obligation to not accept payment or other consideration for financial services if at the time of accepting the payment there were reasonable grounds for believing that the person will not be able to supply the financial services within the period specified." It is open to the commissioner to find that senior management of CBA, CFPL and Count "had been aware for at least 18 months before the breach notices were given of the likelihood that ongoing services were not being provided to customers who were being charged ongoing service fees," Orr explained. "It is therefore open to find that each of CFPL and Count may have contravened their obligations to report as soon as practicable and in any event within ten business days of becoming aware of the breach or likely breach."Nailing the issues, Orr went on: "It is open to the commissioner to find that this conduct was attributable to the remuneration practices of CFPL and its advice licensees."Marianne Perkovic, the bank's executive general manager "accepted thatCFPL's remuneration and performance targets were not aligned so as to ensuredelivery of service," Orr noted."It was only in 2015 that CFPL changed its remuneration policy to align remuneration and performance targets to ensure delivery of service."It is also open to … find that the conduct in question was attributable to acultural tolerance on the part of CBA and its advice licensees of risks and conductthat were potentially detrimental to clients but which were to the financial advantage of CBA through its advice licensees."