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Royal Commission

into Misconduct in the Banking, Superannuation and Financial Services Industry

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Royal Commission| direct

Tag: direct

Consumer lending: Direct lending

February 12, 2019February 12, 2019 wordflow

Recommendation 1.1 – The NCCP Act The NCCP Act should not be amended to alter the obligation to assess unsuitability.

Recommendations Summaryconsumer, direct, lending, obligation, recommendation, unsuitability30 Comments

1 Direct lending under the NCCP Act

February 12, 2019February 12, 2019 wordflow

Direct lending is a core business of banks. The issues that emerged during the Commission in relation to direct lending were of two kinds: issues about compliance with existing norms of conduct (both statutory and voluntarily assumed under the Banking Read More …

Bankingbank, business, compliance, conduct, direct, issue, kind, law, lending, norm, norms, point, provision, relation, starting29 Comments

Navigation

  • Introduction
  • 1 Direct lending under the NCCP Act
    • 1.1 The existing provisions
    • 1.2 Compliance with existing provisions
  • 2 Intermediated home lending
    • 2.1 Home lending through mortgage brokers
    • 2.2 Trail commissions
    • 2.3 Best interests duty
    • 2.4 Do more?
    • 2.5 Brokers as advisers
    • 2.6 Aggregators
    • 2.7 Introducers
  • 3 Intermediated auto lending and associated issues
    • 3.1 Flex commissions
    • 3.2 Relying on the retail dealer
    • 3.3 Capitalising add-on insurance
  • 4 Access to banking services
  • 5 Lending to small and medium enterprises
    • 5.1 The lending framework
    • 5.2 The 2019 Banking Code and the definition of ‘small business’
    • 5.3 Guarantors
    • 5.4 Loan renewal and enforcement
    • 5.5 Agricultural enterprises
  • 6 Enforceability of industry codes
    • 6.1 Enforcing the code
    • 6.2 The purpose of industry codes
    • 6.3 Identifying the enforceable code provisions
    • 6.4 The proposed model: Codes more broadly
  • 7 Processing and administrative errors
    • 7.1 Identifying processing and administrative errors
    • 7.2 Preventing processing and administrative errors
  • Conclusion
  • An addendum: Bankwest

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