Lessons to leverage in implementing the Codes of Practice and enhancing Code compliance across financial services
Regulation of the Australian financial services industry is multi-faceted, with competing obligations and requirements across legislation, regulation, and the industry Codes of Practice. In the wake of the shifting culture across the industry over the past few years, and the need to embed a customer-centric approach, the Codes of Practice have become increasingly important in improving service standards and supporting positive customer outcomes.
While the Banking Code of Practice (‘BCoP’), the General Insurance Code of Practice (‘GICoP’), and the Life Insurance Code of Practice (‘LICoP') (collectively ‘the Codes’) are established elements of the financial services regulations, changing regulatory expectations and recent changes to enforceability have placed a spotlight on subscribers’ Code compliance.
The Codes aim to serve the common purpose of supporting better customer outcomes, as demonstrated by the below focus area, they are however at different points in their implementation and operationalisation by subscribers, and enforceability by the regulator.
This blog explores some of the challenges faced to date by subscribers of the Codes, and insights and learnings for firms to consider in enhancing Code compliance across the industry.
1. Final Report Independent Review of the Banking Code of Practice November 2021
2. Significant Breach as outlined in General Insurance Code of Practice 5 October 2021, Part 16: Definitions
3. BCCC Report: Bank's compliance with the Banking Code of Practice–Jan to June 2021,page 9
4. Living the Code: Embedding Code obligations in compliance frameworks, page5; Monitoring Compliance with the Life Insurance Code of Practice 2020-21 Retrospective, page 4