Some subscribers to the Customers Owned Banking Code of Practice, which came into force in November last year, have faced “transition challenges” meeting their new obligations, an implementation review has found.

The Customer Owned Banking Code Compliance Committee has released a review of industry’s introduction of the new code, reporting that there is a need for more comprehensive system changes and more communication with members.

The code has 55 subscribers, although four were granted extensions until later this year.

The new code, which replaces the 2018 version, puts greater emphasis on support for vulnerable customers and establishes obligations for more inclusive banking products.

Expanded protections include commitments to provide accessible banking services for older and First Nations customers, people with a disability and customers who speak English as a second language.

Code subscribers must take additional care in circumstances involving disability, elder abuse and domestic violence. There are expanded protections for guarantors.

The COBCCC said subscribers had focused their implementation work on staff training, with less attention to systems and processes.

Seventy-six per cent had done some form of staff training and 62 per cent had updated their policies. But only 38 per cent had made system changes to allow for monitoring of new code obligations, such as better identification of customers experiencing vulnerability.

The COBCCC said: “Training is just one element of a good compliance framework. To support and underpin the training, subscribers must have strong systems and processes. Without them, breaches of the code may go undetected.

“We strongly encourage all subscribers to take the opportunity to closely examine these mechanisms as part of post-implementation reviews.”

The BCCC said some subscribers reported “challenges” interpreting new obligations under such headings as inclusive banking, vulnerability, and the enhanced requirements for guarantors.

“It is reasonable for code provisions to challenge providers, otherwise performance will never be enhanced. It is important for all subscribers to ensure they have a clear and consistent view about what the code requires.”

While most subscribers have updated their websites to include reference to the new code, fewer than half have communicated with their members about new code obligations. The COBCCC recommended a comprehensive communications campaign as good practice.

It said most subscribers planned to conduct post-implementation reviews but it is concerned that some of those reviews will have a narrow scope, focusing on compliance but not doing any “gap analysis”.