In this part of the Report I will deal with conduct and issues relating to what may loosely be described as ‘traditional’ banking services. In the Interim Report, I pointed out that the traditional business of banking comprised lending, deposit taking and the provision of transaction services.
Bank‑owned entities have played a prominent role in matters that are the subject of this Report in connection with financial advice, superannuation and insurance. Chief among these issues has been the charging of fees for no service. I will deal separately with those sectors of the industry and then, at the end of the Report, draw together what I consider to be overarching issues, causes and recommendations about culture, governance, and the management and control of regulatory, compliance and conduct risks in the various sectors of the industry.
In dealing with the conduct and issues that have emerged in connection with ‘traditional’ banking services it is important to deal separately with direct lending under the National Consumer Credit Protection Act 2009 (Cth) (the NCCP Act), with intermediated home and automotive lending (and associated issues), with access to banking services, with lending to small and medium enterprises, with the enforceability of the 2019 Banking Code and with what the banks referred to as ‘processing’ or ‘administrative’ errors.
 FSRC, Interim Report, vol 1, 74.
 Malcolm Edey and Brian Gray, ‘The Evolving Structure of the Australian Financial System’ (Paper presented at The Future of the Financial System Conference, H C Coombs Centre for Financial Studies, Kirribilli, 8–9 July 1996) 8–9 <www.rba.gov.au/ publications/confs/1996/pdf/conf-vol-1996.pdf>.