FBAA defends brokers against mortgage survey

From Mortgage Professional Australia. The Finance Brokers Association of Australia (FBAA) has defended the broker channel against claims by a UBS survey indicating some brokers are advising clients to misrepresent figures on their applications.

Bank-Lens

The FBAA’s Peter White said the survey claimed that about 6%, or 84 of the 1228 borrowers surveyed said the broker directed misrepresentations in loan applications.

According to the survey, 60% of the borrowers in the sample secured their mortgage from a broker, slightly higher than the nationwide figure.

UBS stated that participants were surveyed anonymously and said, “given the large number and spread of participants, these findings are statistically significant with a 95% degree of confidence”.

The report also stated, “If anything, we believe this data is likely to understate the level of misrepresentation as some respondents may not feel comfortable stating they were not completely factual and accurate even in an anonymous survey.”

But White has questioned the accuracy of the whole survey, saying the amount of people purportedly surveyed represents only an estimated 0.09% of all mortgages settled over the two year time period, and a number of the figures in the survey were inconsistent with APRA data and Industry data.

He also said there was “zero credibility” in the claim of a borrower who admits to falsifying documents.

“Let’s be honest – if you are admitting to misrepresentation on a legal document it’s very easy to blame someone else and claim they made you do it.

“This really should not be taken seriously, particularly with the stringent regulations around the broking sector and responsible lending criteria which brokers adhere to.”

White said the FBAA would not tolerate any unethical behaviour and that there was no incentive for brokers to misdirect clients.

“Our own data tells us that only a miniscule percentage of our members have had action taken against them and that overall, brokers are doing the right thing.

“I believe that not only are these figures wrong but that they are based on claims that can never be verified.

“It is a shame for the industry that this sort of misinformation is publicised but I am confident the regulators, the industry and the public know the truth.”

Do the governance experts at the World Bank have a governance problem?

From The Conversation.

As a source of financial and technical assistance to developing countries around the world, the World Bank should be an example of how to manage transparently, with accountability and inclusion. Yet the bank isn’t following the principles of good governance when it comes to the bank itself.

globe-open

If the World Bank wants to stay relevant and a part of the process of creating global agreements, it needs to keep up with other agencies that are improving transparency. If it doesn’t, it risks becoming redundant to similar international agencies like the Asian Infrastructure Investment Bank.

One striking example of how the bank is falling behind is in the selection process of its president. The incumbent president of the World Bank, Jim Kim, was recently appointed for a second term in a process that was largely devoid of transparency.

The selection process has been mired in intense internal lobbying from both the president and stakeholders in his candidacy, both through personal visits to countries such as China and India and then at multilateral forums such as the G7 meeting in Japan this May. As incumbent, the president has the power to make deals and promises contingent upon his selection.

The process normally lasts several months so that countries might offer alternative candidates, but this was cut to mere weeks this time around. That made it impossible for other countries to put forth other qualified names.

What is the biggest consequence of the World Bank refusing to apply its own medicine? Perhaps the most severe effect is the resulting organisational disgruntlement.

The World Bank Staff Association has openly articulated its disappointment in a published letter:

“We preach principles of good governance, transparency, diversity, international competition, and merit-based selection. Unfortunately, none of these principles have applied to the appointment of past World Bank Group Presidents.”

Discontent among senior and mid-level staff is rife. In four years, the president’s office has had five chiefs-of-staff.

Heads of departments are leaving. According to a survey, World Bank staff also fear blowing the whistle. Only a third believed that senior management created “a culture of openness and trust”.

It’s been a problem for a while

The World Bank’s governance problem has been a concern for many years. For the past three decades at least, academics have called for the bank’s leadership selection process, its constitutional rules, decision-making procedures, staffing and expertise and the balancing of stakeholders’ rights to be reconsidered.

In the early 1990s the World Bank became a strong advocate of high standards of “legitimacy”, “representation” and “accountability” for the countries that sought to borrow from the bank. These standards were given the collective title of “good governance”.

Yet the World Bank has had a difficult time demonstrating this in its own workings. Part of the problem lies in what the World Bank considers participation and inclusion – a problem of double standards.

Typically, the World Bank has thought of “participation” as informing stakeholders of what it is doing, rather than taking input from stakeholders in the decision-making process. For example, the bank tells stakeholders who should be president, rather than having a transparent selection process where stakeholders have a say.

This extends to other aspects of the bank, such as in the priorities and type of research it conducts. This should reflect the bank’s diverse stakeholders, but that’s often not the case.

For example, during the presidency of Ronald Reagan, when the neoliberal agenda came to the front-and-centre of political discourse, the World Bank disfavoured research on debt relief because it was an approach in line with the political left.

The risk of becoming redundant

Consider the United Nations, a similar multinational body which is also 70 years old. It has gone through far more reform, which is why UN candidates are being more transparently elected over a longer time. While it too does not have a fully transparent process, at least UN nominees are able to present a stronger case for their candidature and devise more thorough plans, while also making these plans more evident to all stakeholders.

In the longer run, the question of exercising good governance is part of the World Bank’s need to stay relevant. The World Bank operates in a world very different from that which existed when it was created. This was immediately after the second world war, when the allied countries were assigned voting shares based on their gold and dollar holdings.

If important countries consider the World Bank to be a relic of a bygone era, they will find alternative mechanisms to conduct multilateral engagements. This is already happening through powerful new institutions such as the China-led Asian Infrastructure Investment Bank, which has begun approving lending in conjunction with other banks for projects in countries such as Pakistan.

The World Bank promised as far back as 2011 to improve transparency, but changes haven’t been made.

The World Bank Staff Association recommends the following:

“an international call for candidates, women and men, with clear qualification criteria, followed by nominations and a long-listing process handled by a credible search committee, together with a transparent interview and selection process”.

Through such changes, the governance experts might finally begin to resolve their own governance problem.

Author: Usman W. Chohan, Doctoral Candidate, Policy Reform and Economics, UNSW Australia

ABA On The Inquiry This Week

The Australian Bankers’ Association today acknowledged the House of Representatives Standing Committee on Economics’ Inquiry this week had provided a valuable forum for major banks to respond to issues of interest to the Committee and outline the progress already being made to address them.

Complainy

Steven Münchenberg, Chief Executive of the ABA, said the banks involved had welcomed the opportunity to provide their perspectives on various industry issues, challenges and opportunities.

“As an industry, we know we haven’t always lived up to the expectations of all of our customers and the wider community. The banks are acknowledging those issues and more importantly they are addressing them,” he said.

“The Inquiry this week raised a wide range of important issues, many of which are already being addressed by the Federal Government or industry initiatives.

“There were also a number of ideas and proposals raised that merit further substantive consideration and the banks will be evaluating these at the next meeting of the ABA Council.

“That said, the banking industry is committed to taking action right now to deal with major issues and deliver better outcomes for customers,” he said.

Mr Münchenberg said the banking industry’s six point reform package launched in April 2016 included independent reviews into:

  • Pay structures that put incentives for bank staff ahead of customer needs. The review is being conducted by former Australian Public Service Commissioner Stephen Sedgwick AO with a final report expected in March 2017.
  • The Code of Banking Practice to lift standards of conduct and culture. The review is being conducted by former ASIC executive Phil Khoury who is due to report by December 2016.

The next progress report on the delivery of the industry’s reform package will be made by an independent expert, former Auditor-General Ian McPhee AO PSM, by 21 October 2016.

The banking industry’s six point reform package is running in parallel with separate Government reviews into:

  • Finding faster and better ways for customers to get justice if they feel they are treated unfairly (the Ramsay Review, which reports in March 2017).
  • The treatment of small business customers (the Carnell Review, which is due to report by the end of 2016).

Mr Münchenberg said the ABA and the banks intend to set out detailed responses to the matters raised by the Committee in the coming weeks, including responses to various questions on notice that were taken over the past three days, so that the Committee would be in a position to finalise its recommendations.

“We believe there is an opportunity to accelerate the timetable on a range of initiatives and we will be exploring this with our members and with the Committee, particularly on matters where there is general agreement on the need for action sooner rather than later.”

NAB Apologies For The Inconvenience

Not sure if this is a first, but this video is now doing the rounds. As a response to the systems problem, well done NAB! Now, when is NAB to front that economics committee?

Acknowledging the problem and apologising is a good thing – something which signals a cultural change, but in this digitally connected world, perhaps we also need to know what happened, and most importantly, what will change to ensure we do not get the same again.

Should Bank Executives Take A Pay Cut?

Newly released piece from the Bank Doctor arguing that bank executives should take a pay cut.

Scandals involving the conduct of banks and bankers are a worldwide phenomena. This remarkable You Tube video shows a bank manager from China’s Rural Commercial Bank publicly spanking team members for their failure to meet performance targets. Before they get their comeuppance the manager asks them why they deserve to be punished. “I have not exceeded myself” one employee said. “I am not brave enough” another replied.

And over the last 5 years employees of Wells Fargo bank, which incidentally was named the best bank in the USA in 2015, have opened more than 1.5 million unauthorized deposit accounts and issued more than 500,000 unauthorized credit card applications.

This wide scale fraud on customers stemmed from an aggressive cross selling sales ideology lead by Wells Fargo’s CEO whose mantra was  “eight is great” meaning the goal was to get eight products into the hands of each customer bank. But as employees struggled to meet demanding quotas and satisfy even more demanding managers they began to cut corners and opened deposit accounts and credit cards for unsuspecting customers.

This scandal was uncovered not by the bank’s internal audit department or by a whistleblower (that’s another story) but by investigative journalists. And the response from Wells Fargo management?  They sacked around 5,300 employees who had been involved in the schemes, announced the abolition of sales goals in its retail banking business starting from 2017 and paid $185m in fines to city and federal regulators. Meanwhile, the executive who ran the unit responsible for the millions of fake accounts recently retired having received an estimated $125m in payments from the bank.

It wasn’t until a public outcry that the Wells Fargo board took some action against the senior executives responsible but even this was nominal – the CEO who has earned $83m over the last three years will forego $41m in unvested stock and the department unit head will forego $19m leaving her a measly $106m!

Australian banks have been caught up in a number of well-publicised scandals including investment advice and insurance. We regularly hear of the pressure bank staff are under to meet sales targets and although punishments like spanking and mass sackings have not been inflicted upon Australian bank staff, they like the customers have also suffered from poor judgement and decisions made by their leaders.

At the risk of stating the obvious, the problem is not employee misconduct. The problem is the executives who have created and perpetuated a culture that places their own and their banks short term financial interests ahead of those of other stakeholders. This extends to the board members who have countenanced this.

The newly appointed RBA Governor Philip Lowe recently bemoaned the direction banking has taken in recent years noting that “historically banking, has been a profession — a profession of stewardship, custodians, service, advisory, counsellor. It is not a marketing or product-distribution business, banking is a profession.”

He added, “if there was one thing that I could focus on and it’s not my responsibility, it’s not the Reserve Bank’s responsibility, is making sure the remuneration structures within financial institutions promote behaviour that benefits not just an institution but its client.”

The remuneration debate should not start with incentives paid to tellers or financial advisors. Westpac’s Brian Hartzer has just announced the removal of all product related sales incentives for tellers and NAB has committed to moving away from performance based pay for customers service and support staff. But changing the way staff are remunerated might change their behaviour but it won’t win back the trust banks have lost. Nor will forcing banks to separate their wealth and banking divisions.

What would start to change the way the community thinks about banks is CEOs showing real leadership when it comes to executive remuneration. And here we are not just talking about CEOs but also the executives below the CEOs. Take CBA for example, last year Ian Narev was paid $12.3m whilst the average pay of his eleven direct reports was $3.65m. Incidentally the RBA Governor is paid a tad over $1m pa. In addition to their big salaries, bank execs hold shares and performance rights which in most cases are worth millions of $s. And its not just what they get paid whilst at the bank, its also what they get when they leave. For instance, Andrew Thorburn’s direct reports at NAB have termination clauses in their contracts guaranteeing them average payouts in excess of $500k.

It is galling that bank executives can be paid so handsomely when the bank has not performed. ANZ’s Mike Smith was paid $88m over his eight year reign during which ANZ was the worst performing big four bank. Its share price went backwards by 10 per cent over this period.

It is equally galling that bank executives receive generous exit arrangements and then the bank underperforms. Gail Kelly took home $11.8m in her last four months at Westpac on top of $55m in shares and since her departure in November 2014, Westpac’s share price has fallen 7 per cent.

Where are the Boards?
What do the boards of banks have to say about this or are they too part of the problem? Bank chairmen are paid around $1m pa and non-executive directors receive around $350k pa plus income from the other directorships and roles they all hold.

CBA’s Harrison Young is the exception. He is the only one of the 32 big four bank non-executive directors to hold no other directorships. Mr Young is well regarded for his strong public statements on banking culture and ethics. One of his many thought provoking statements concerns bankers pay… “compensating bankers so well that the most ambitious people in the world want to be bankers probably means that the wrong people will run a lot of banks.”

What should be done & who is going to do it?
Self-regulation is the preferred starting point for reform but most Australians seem to have concluded that the banks alone cannot be trusted to fix the problems. Many go as far as to say a Royal Commission is needed and while I can understand their angst I don’t believe this is the most efficient solution for reforming the industry.

This week’s parliamentary inquiry sessions represent an opportunity for bank leaders and politicians to lift the standard of debate and understanding of the complexities involved in an industry that is so central to the nation’s success. Based on yesterday’s session with CBA, it appears these “grillings” will be nothing more than a political show trial where a handful of politicians try to give defensive bank leaders the rounds of the kitchen over bank profits, blah blah. It might suit the political aspirations of politicians to continue to engage in one of Australia’s favourite pastimes but it does nothing to make our banking system safer and fairer for all concerned. Governments cant legislate to improve trust in our banks, that can only be initiated by the banks themselves and this will require bank leaders to make some meaningful commitments to change and then most importantly walking the talk.

Here are six suggestions the bank CEOs might want to consider:

1. Announce an immediate and meaningful pay cut. A freeze is not a pay cut.

2. Get rid of bonuses for senior executives at least for the foreseeable future to see what if any impact this has. It is interesting to note that John Cryan, CEO of the beleaguered Deutsche Bank, noted “I will not work any harder or any less hard in any year, in any day, because someone is going to pay me more or less.”  He candidly stated that “many bankers still get paid too much for what they do and still believe they should be paid entrepreneurial wages for turning up to work with a regular salary, a pension and probably a healthcare scheme and playing with other people’s money.” Only time will tell what price John Cryan pays for the failures within Deutsche Bank.

3. Implement policies that enable clawbacks of bonuses and payouts when there is legacy underperformance.

4. Greater encouragement and protection for whistleblowers. Whilst progress has been made in encouraging and supporting whistleblowers, we still have a long way to go.

5. Be totally frank about the inherent conflict between meeting the needs of shareholders, customers and employees. Brian Hartzer says “we create value for Westpac when we help customers create value for themselves, that’s why I believe that over the long term, there is no gap between the interest of Westpac and the interest of our customers”.  But as John Maynard Keynes famously said “in the long run we are all dead” and how many bank execs last the distance anyway? The community believes banks are run by people who put profits ahead of all else but the public also understands the inherent difficulty in trying to satisfy multiple stakeholders. The real challenge for the banks is getting the balance right and as Andrew Thorburn astutely observed “if we don’t achieve the balance, the potential impacts are extremely serious.”

6. Boards need to do more in setting the standards. To date they have not done enough. The standard you walk past is the standard you accept. A good starting point might be appointing more directors like CBA’s Harrison Young.

Reproduced with permission.

Banks make millions in delaying interest rate cuts

From The Conversation.

When Australia’s central bank moves interest rates as part of its monetary policy, it’s not just politicians who stand to lose if banks don’t follow suit.

Retail lending markets form an integral part of the monetary policy transmission mechanism. If interest rate rises are passed on at a different rate to cuts it can adversely affect the efficacy of expansionary versus contractionary monetary policy.

In August 2016, APRA data showed the big four Australian banks held 83% of the home loan market (including both the owner occupier and investment categories).

At an individual level, the ability and willingness of lenders to pass on the official interest rate cuts to borrowers depends on many factors. These include exposure to overseas funding sources, market power, the funding mix, reserves and the extent of securitisation. But it’s also clear delaying interest rate cuts can significantly impact their bottom line.



According to my analysis, the big four banks can make approximately $A8.6 million per day as a group if they do not fully pass onto borrowers a hypothetical 0.25% cut in the RBA’s cash rate.

More specifically, if ANZ, CBA, NAB and Westpac manage to postpone lowering their mortgage interest rates say by 10 days, they can potentially make an extra A$16, A$28, A$16 and $A26 million dollars in profits, respectively.

Previous studies on mortgages, small business loans and credit card interest rates have found significant evidence for the “rockets and feathers” hypothesis. That is, when the cash rate increases, various lending rates shoot up like rockets but when the opposite occurs they go down like feathers.

In my research I used monthly data (2000-2012) for 39 bank and non-bank financial institutions including 7 building societies, 15 Australian-owned banks, 3 foreign subsidiary banks, 13 credit unions, and 1 major mortgage broker. The research found the mortgage interest rate spread of all lenders rose after the 2008 global financial crisis, albeit to varying degrees.

In general, the research shows most building societies and some credit unions can offer more competitive home loans than banks.

There is no significant relationship between lenders’ markups and the level of over the counter customer service since the 2008 financial crisis. This is an important observation as the mortgage spreads of larger lenders are typically higher than those of their smaller non-bank counterparts. This puts lie to the view that the relatively higher mortgage interest rates of the larger banks in Australia are justified by higher overhead costs associated with the running of their large branch networks.

Author: Abbas Valadkhani, Professor of Economics, Swinburne University of Technology

ABA Rejects View That Bank Wealth Advisors Sidestep FOFA

The Australian Bankers’ Association has today strongly rejected the claim by Industry Super Australia that banks ‘sidestep’ Future of Financial Advice protections when advising customers on superannuation.

Investment-Pic2They were reacting to strong claims made today by ISA:

The big four banks have been luring people away from industry super funds and into poorer performing super products, an industry super advocacy group claims.

Industry Super Australia says there has been a significant increase in people signing up to bank-owned super funds as the major banks ramp up their over-the-counter superannuation sales advice.

Industry Super’s chief executive David Whiteley says the banks’ super products typically delivered lower investment returns than industry super funds.

“There’s a real risk now of people walking into a bank and ending up as a member of a super fund that is worse than the fund they were already a member of,” he told AAP on Tuesday.

“The implication for the consumer is that they’ll retire with less, or they may have to work longer, or they will become more reliant on the aged pension.”

Mr Whiteley said the group’s analysis of data from Roy Morgan Research found that the big four banks had doubled their over-the-counter super sales advice between 2011 and 2015.

“The figures show direct advice is growing quickly and at the expense of traditional channels including financial advisers,” he said.

The research also found that customers were being switched from funds with higher net satisfaction and performance into funds with lower satisfaction and performance, he said.

And, unlike financial advisers, bank staff, who are often given incentives to sell the super products, don’t have to meet best interest obligations, he said.

“General advice direct from a bank does not need to meet the best interest obligations and it is likely the banks are using this and linked sales incentives to funnel customers into underperforming funds.”

Industry Super Australia wants banks to be required to perform a better-off test to demonstrate a customer would not be worse off if they switched funds.

It also wants a ban on all sales incentives relating to superannuation.

ABA responds:

“It is ridiculous to claim that the increase in major banks’ superannuation market share points to ‘obvious market failure’,” ABA Executive Director – Retail Policy Diane Tate said.

“Banks have made significant investment to change their practices and systems to comply with the Future of Financial Advice laws, banning conflicted remuneration and introducing a best interest duty,” she said.

“We also support new legislation to raise education, ethical and professional standards for all financial advisers.”

Ms Tate said customers want a one-stop-shop for their basic banking and financial services.

“Banks are using technology to make sure their customers have the convenience of being able to access all their products and services in one place, like using their smartphone, and with the confidence their money is secure.

“Banks have raised the competency and ethical standards of financial advisers. For example, just last month the industry announced a new way of hiring financial advisers to stop advisers with poor conduct records moving around the industry.

“We have also established an independent review into how banks pay staff and reward them for selling products and services,” she said.

“Industry super funds are competitors with banks. If only this was a campaign about doing the right thing by customers; but really it is just a competitive play,” Ms Tate said.

Simpler account switching would help keep our banks honest

From The Conversation.

When the chiefs of Australia’s largest banks appear before the Standing Committee on Economics this week it’s likely they’ll be asked about the current level of competition in retail banking.

One of the objectives of competition law in Australia “is to enhance the welfare of Australians through the promotion of competition”. Promoting competition means making sure there is vibrant competition. This means ensuring that competitiveness is enhanced once competition is established.

Reluctance to change

Existing market players generally resist the changes needed to make a sector more competitive. This resistance is driven by the rational fear that a more competitive sector will lead to lower margins and loss of market share.

It seems odd, but in the early days of text messaging it was only possible to send texts to people on the same network. Interconnection of networks was driven partly by commercial opportunity, but mainly by the prospect of regulatory intervention. In mobile telecommunications, mobile number portability was introduced in Australia and elsewhere as a result of similar pressures.

Competition regulators know that competitiveness is higher when it’s easier for a consumer to switch providers. Of course, that does not mean there will be mass switching. Consumers switch when there is a prompt. This might be the end of a contract, or poor (uncompetitive) service from a provider.

Switching banks

In Australia, in common with other parts of the world, switching between retail banks presents hurdles. It’s just a difficult process, even with the help of the bank to which you are switching. A mixture of direct credits, direct debits, mortgage or rent payments and links to credit cards means that switching banks is complex and hard.

One solution to this problem is bank account number portability. The idea is that you can switch your bank without changing your bank account number – just like switching mobile providers.

This could be implemented by having a single independent bank account number database (iBAND), which links account numbers with people. Each bank would then check the iBAND when making a payment as depicted below.

iBAND Rob Nicholls

The UK experience

Even this might be a bit more complicated than is needed. The Australian Payment Clearing Association’s “New Payments Platform” offers a range of identifiers for people in addition to bank account numbers. This could also form the basis for portability and switching.

In the UK, the Current Account Switch Service (CASS) is a free-to-use service for consumers to simplify switching current accounts. This service is designed to increase competition, competitive entry and consumer choice.

There is a Current Account Switch Guarantee to enable switching to occur within seven days. Since the scheme started in 2013, there have been 3 million switches and 99% of these occurred within seven days.

The consumer education process that accompanied the introduction of CASS in the UK means more than three-quarters of all current account holders are aware of the service.

Data can help

The other issue with switching is knowing whether the deal you will get with the new bank is better. What would be ideal is to have a way of comparing your existing bank or banks and credit card providers with other financial institutions. One way of doing this is by having a standardised form of metadata.

If you wanted to do a comparison, you could download a set of anonymised metadata that described your banking needs. This could then be compared on a platform with other providers.

The UK’s Competition and Markets Authority (CMA), in its final report into the UK retail banking system, suggests that the provision of open banking applications programming interfaces (API) would facilitate such an exchange of data. The broad approach is set out below.

CMA approach Rob Nicholls derived from CMA report

The idea is that each bank would present a common interface to external systems through the API. This would allow the banks to create and use apps to enhance the consumer experience. However, it would also allow third parties to be intermediaries or to compare the banks’ offerings.

Switching, innovation and productivity

In its submissions to the Harper review of competition law and policy, CHOICE argued that such a scheme would encourage innovation. The ACCC put the case that “initiatives to allow consumers to effectively use their information … have the potential to assist consumers to make better choices and drive competition”.

The UK government has put consumer switching at the heart of its approach to increasing productivity. It regards this step as critical to open and competitive markets with the minimum of regulation.

Both the Harper review and the Murray inquiry into the financial system found that competition should be at the forefront of regulatory consideration. One way to improve competitiveness in banking is to facilitate both switching and consumer information.

But perhaps the best way to determine whether there is a need to promote competitiveness would be for the ACCC to commence a market inquiry on retail banking. This could have the aim of developing initiatives to stimulate additional competition.

Author: Rob Nicholls, Lecturer, UNSW Australia

NAB’s Latest Financial Advice Customer Response Update

NAB has today provided an update on its financial advice Customer Response Initiative – a commitment made to improve transparency for Wealth advice customers.

Bank-Concept

Since February 2015, NAB has made $6.5 million in payments to 251 customers after resolving their claims for compensation. This uplift in payments to customers follows a significant investment by NAB into its capacity to investigate and resolve customer complaints.

NAB’s public commitments made in 2015 and the current status for each commitment is provided below:

Our commitment: Where there is professional misconduct in wealth advice we will move to write to all customers, where misconduct has occurred in the last five years.
Current status: On 21 October 2015, we announced that we had started to write to customers as part of the Customer Response Initiative. We are writing to groups of customers where there is a concern that they may have received inappropriate advice since 2009.

Our commitment: We will respond to all new customer complaints within 45 days.
Current status: We have committed to responding to new complaints within 45 days, and we are tracking well against this commitment.

Our commitment: We are going to add independence into our complaints and whistleblower process.
Current status: In addition to appointing an independent officer to sit on our own whistleblower committee, we have introduced six different measures to increase independence into our complaints resolution. They are:

  • appointing KPMG to help design the Customer Response Initiative
  • appointing an independent Customer Advocate for wealth advice
  • appointing Deloitte to review and report on our progress
  • Deloitte’s reports to us will be provided to ASIC – the independent regulator
  • offering customers $5000 to source their own additional independent financial advice if they need help understanding the outcomes of the CRI
  • negotiating a streamlined review process by FOS if customers do not accept the outcome of the Customer Response Initiative.

Our commitment: We will advise ASIC of all advisers who leave, with the categorisations and reasons of their departure.
Current status: In addition to our reporting obligations for the ASIC financial adviser register, we have implemented a process to notify ASIC in writing of any adviser departures, where we have had compliance concerns about that adviser.

Our commitment: We committed to look to remove confidentiality orders from settlements and to write to customers to advise them these orders had been lifted.
Current status: While our previous confidentiality obligations did allow customers to talk to the media, ASIC or advocacy groups about the facts leading to their complaint with NAB, we acknowledge they were written in such a way where customers may not have been aware of this. So, as part of our Customer Response Initiative, to remove any ambiguity, we have started to write to appropriate customers to advise them that past confidentiality obligations have been lifted. Furthermore, these clauses are no longer included in NAB Wealth Advice Deeds.

In addition to our 2015 commitments, NAB is committed and progressing to the package of industry initiatives announced by the Australian Bankers’ Association (ABA), aimed at enhancing our customers’ experience with us, and reinforcing the banking sector’s standards of service, integrity, trust and ethics.

When NAB last provided an update on its Customer Response Initiative in October 2015, we explained that since February 2015 to October 2015, NAB had made $1.7 million in payments to 87 customers after resolving their claims for compensation

Another Revenue Challenge

According to Moody’s the new Focus on US Banks’ Sales Practices Is Another Revenue Challenge.

Last Tuesday, Thomas Curry, head of the US Office of the Comptroller of the Currency (OCC), indicated during testimony before the US Senate Banking, Housing and Urban Affairs Committee that his agency will conduct a horizontal review of sales practices at the nation’s largest banks. Later, Consumer Financial Protection Bureau (CFPB) Director Richard Cordray added that his agency would be “doing a joint action” with the OCC.

We believe regulators will conduct a particularly thorough review of the industry’s sales practices in response to the media and political spotlights on Wells Fargo & Company’s (A2 stable) recently disclosed wrongdoings, the unauthorized opening of up to 2.1 million deposit or credit card accounts. For the banks, the additional regulatory focus is credit negative because it will increase scrutiny on deposit fees, which are a meaningful contributor to their revenue.

Deficient sales practices have only been highlighted at Wells Fargo and nowhere else. Nonetheless, in underscoring the need for a broader review, Mr. Curry highlighted the importance of incremental product sales and fees, noting that protracted low interest rates put the industry, not just Wells Fargo, “under enormous margin pressure.”

As shown in Exhibit 1, Federal Deposit Insurance Corporation (FDIC) data show that service charges on deposit accounts are significant for the industry, totaling nearly $34 billion in 2015, or 14% of total noninterest revenue. Large as this number is, it has fallen in absolute terms and as a percentage of non-interest income since the 2008-09 financial crisis, primarily because of heightened regulation. The additional exams announced last week will only reinforce existing scrutiny over specific revenue sources, such as overdraft fees.

moodys-rev-1

The misconduct at Wells Fargo has put all large banks in the regulators’  crosshairs. Exhibit 2 shows that for most large banks, deposit service charges are a meaningful contributor to overall revenue; that is, the combination of net-interest income and non-interest income. Specifically, for the first six months of 2016, 16 large banks reported a median contribution to total revenue of 6.7% from service charges on domestic deposit accounts, with one bank in the group, Regions Financial Corporation (Baa3 review for upgrade), earning 12% of its total revenue from this source.

moodys-rev-2

Although some senators at last week’s hearing highlighted their worry that inappropriate sales practices could be widespread, that determination has not yet been made. Regardless, we believe the revelations at Wells Fargo will cause banks to tread cautiously before rolling out more aggressive sales initiatives in the current environment. That alone will constrain their revenue growth