Tag: CBA

ASIC accepts court enforceable undertaking from CBA

ASIC says Commonwealth Bank of Australia (CBA) has entered into a court enforceable undertaking with ASIC in relation to their bank bill trading business and their participation in the setting of the Bank Bill Swap Rate (BBSW), a key benchmark and reference interest rate in the Australian financial system.

As part of the undertaking, CBA will pay $15 million to be applied to the benefit of the community and $5 million towards ASIC’s investigation and legal costs.

CBA will also engage an independent expert to assess changes CBA has made (and will make) to its policies, procedures, systems, controls, training, guidance and framework for the monitoring and supervision of employees and trading in Prime Bank Bills.

On 21 June 2018, the Federal Court in Melbourne imposed pecuniary penalties totalling $5 million on CBA for attempting to engage in unconscionable conduct in relation to BBSW. CBA admitted to attempting to seek to affect where BBSW set on five occasions in the period 31 January 2012 to 15 June 2012.

CBA also admitted that it failed to do all things necessary to ensure that they provided financial services honestly and fairly and that its traders were adequately trained.

Justice Beach of the Federal Court noted the terms of the court enforceable undertaking and, in imposing the pecuniary penalty of $5 million, stated ‘…that sum together with the other payments all totalling $25 million should be an adequate denouncement of and deterrence against the unacceptable trading behaviour of individuals within CBA that ought to have known better and a bank that ought to have better supervised its personnel.’

Background

ASIC commenced legal proceedings in the Federal Court against CBA on 30 January 2018 (refer:18-024MR), alleging that on three specific occasions between 31 January 2012 and October 2012, CBA traded in a manner that was unconscionable and created an artificial price and a false appearance with respect to the market for certain financial products that were priced or valued off BBSW.

This followed proceedings in the Federal Court against the Australia and New Zealand Banking Group (ANZ) on 4 March 2016 (refer: 16-060MR), against the Westpac Banking Corporation (Westpac) on 5 April 2016 (refer: 16-110MR) and against National Australia Bank (NAB) on 7 June 2016 (refer: 16-183MR).

On 10 November 2017, the Federal Court made declarations that each of ANZ and NAB had attempted to engage in unconscionable conduct in attempting to seek to change where the BBSW set on certain dates and that each bank failed to do all things necessary to ensure that they provided financial services honestly and fairly. The Federal Court imposed pecuniary penalties of $10 million on each bank.

On 20 November 2017, ASIC accepted enforceable undertakings from ANZ and NAB which provides for both banks to take certain steps and to pay $20 million to be applied to the benefit of the community, and that each will pay $20 million towards ASIC’s investigation and other costs (refer: 17-393MR).

On 24 May 2018,  the Federal Court found that Westpac engaged in unconscionable conduct under s12CC of the Australian Securities and Investments Commission Act 2001 (Cth) by its involvement in setting BBSW on four occasions (refer: 18-151MR). A further hearing of this proceeding on penalty and relief will be held on 12 October 2018.

In July 2015, ASIC published Report 440, which addresses the potential manipulation of financial benchmarks and related conduct issues.

The Government has recently introduced legislation to implement financial benchmark regulatory reform and ASIC has consulted on proposed financial benchmark rules.

On 21 May 2018, the new BBSW methodology commenced (refer: 18-144MR). The new BBSW methodology calculates the benchmark directly from market transactions during a longer rate-set window and involves a larger number of participants. This means that the benchmark is anchored to real transactions at traded prices.

If there is a breach of the undertaking entered into by CBA, then under the ASIC Act, ASIC can apply for orders from the court to enforce compliance.

ASIC accepts court enforceable undertakings from CBA and ANZ over superannuation product distribution

ASIC has accepted court enforceable undertakings from the Commonwealth Bank of Australia and Australia and New Zealand Banking Group under which the banks have agreed to change the way they distribute superannuation products to their customers.

ASIC investigated CBA’s distribution of its Essential Super product and ANZ’s distribution of its Smart Choice Super and Pension product (Smart Choice Super) through bank branches. ASIC found a common practice of offering those products to customers at the conclusion of a fact-finding process about customers’ overall banking arrangements.

CBA’s fact-finding process was called a ‘Financial Health Check’. CBA staff also sometimes helped customers roll over their other superannuation into the Essential Super account at the time of distribution.

ANZ’s fact-finding process was called an ‘A-Z Review’.

ASIC was concerned that the proximity between the fact-finding process and the discussion about Essential Super or Smart Choice Super was leading CBA staff and ANZ staff to provide personal advice to customers about their superannuation.  Branch staff for both CBA and ANZ were only authorised to provide general advice.

Stricter consumer protection laws apply to financial services licensees when their representatives give personal advice about complex financial products such as superannuation than when they provide general advice about those products. This includes the requirement, with personal advice, to give a customer a Statement of Advice and to act in the customer’s best interests. People who give personal advice about complex products are also required to meet higher training standards.

ASIC was concerned that customers may have thought, due to the proximity of the fact-finding process to the offer of Essential Super or Smart Choice Super, that the CBA branch staff or the ANZ branch staff were considering risks specific to the customer when this was not the case.

These court enforceable undertakings prevent CBA from distributing Essential Super in conjunction with a Financial Health Check and ANZ from distributing Smart Choice Super in conjunction with an A-Z Review. They also require CBA and ANZ to each make a $1.25 million community benefit payment. If there is a breach of the undertaking ASIC can, under the ASIC Act, apply for orders from the court to enforce compliance.

CBA chose to suspend the distribution of Essential Super in CBA branches in October 2017.

‘ASIC will continue to proactively monitor how complex financial products such as superannuation are sold,’ ASIC Deputy Chair Peter Kell said.

ASIC’s actions underline the importance for financial services licensees to ensure that customers understand the nature of advice they are receiving about their superannuation.

View the enforceable undertaking

Background

ASIC’s investigation arose following a surveillance conducted in relation to CBA’s distribution of its retail superannuation product, Essential Super and ANZ’s distribution of its retail superannuation product, Smart Choice Super.

These actions are part of ASIC’s Wealth Management Project. The Wealth Management Project was established in October 2014 to lift the standards of major financial advice providers. The Wealth Management Project focuses on the conduct of the largest financial advice firms (NAB, Westpac, CBA, ANZ, Macquarie and AMP).

CBA Withdraws from Low Doc Lending

CBA has announced that it will remove low documentation features on all new home loans and line of credit applications from 29 September, as the bank continues its ongoing move to ‘simplify’ the bank, via The Adviser.

The Commonwealth Bank of Australia (CBA) has told brokers that it is “simplifying” its product suite to ensure that it is “providing a suitable range of products that align with [its] customers’ needs”.

As such, from Saturday 29 September 2018, the big four bank will remove all low documentation features on new home loans and line of credit applications. Should a customer wish to top up an existing home loan or line of credit with the low doc feature, they must provide full financials for all new applications.

All new loans that have low doc feature, including Home Seeker applications, must reach formal approval by close of business on Friday 28 September 2018.

The bank has said that brokers who request an amendment to an application with a removed product or a low doc feature that has not yet reached formal approval by Saturday 29 September 2018 will need to discuss “another product option” with the customer to suit their needs.

Loans must be funded by close of business Friday 28 December 2018.

There are no changes for existing customers that have low doc loans.

The move marks a major change in the lending landscape, but in practice – CBA has not provided true ‘low doc’ loans for some time, requiring more documentation than most historical low doc loans required.

Indeed, this type of loan product makes up a minimal proportion of the bank’s portfolio.

As well as removing the low doc feature, the bank will also remove several home loan products, including:

One-year Guaranteed Rate
Seven-year Fixed Rate loans
12-month Discounted Variable Rate;
Rate Saver products
Three-year Special Rate Saver; and
No Fee Variable Rate

If a customer wants to top up a One-year Guaranteed Rate, Seven-Year Fixed Rate or a 12-month Discounted Rate Home Loan they must complete a switch to another available product that best suits their needs.

An early repayment adjustment and an administrative fee may apply on the One-year Guaranteed Rate and Seven-year Fixed Rate when completing a switch.

Top-up applications for Rate Saver, Three-Year Special Rate Saver and No Fee Home Loans will still be available.

A CBA spokesperson said: “At the Commonwealth Bank, we constantly review and monitor our suite of home loan products and services to ensure we are maintaining our prudent lending standards and meeting our customers’ financial needs.

“From September onwards, we will be streamlining our suite of products to deliver our customers a simplified and competitive range of home loan solutions.”

Highlighting that the bank’s product suite offers “attractive” standard variable rate and fixed rate options, while its extra home loan products offer customers “low interest rates, no monthly fees, and no establishment fees”.

“Whatever our customers’ needs, our network of brokers or home lending specialists can help them find a flexible mortgage and guide them through the entire home buying journey, providing support every step of the way,” they said.

CBA to cut ties with Aussie

From The Adviser.

CBA’s decision to distance itself from Aussie Home Loans via the bundled spin-off of its wealth management business has been labelled a “clean and timely exit” by CEO Matt Comyn.

Any conflicts of interest to be found in the ownership of Australia’s biggest mortgage brokerage by Australia’s biggest bank will soon be a thing of the past.

On Monday morning, CBA announced that it will demerge Aussie, along with several wealth management businesses such as Colonial First State, into a separate company known as CFS Group. That group will list on the ASX.

“Ultimately, we believe that they will perform better outside the Commonwealth Bank Group,” CBA chief executive Matt Comyn said.

“Aussie Home Loans [is] the leading mortgage broking franchise, and we have decided to put that inside the demerged group. It is a very successful business, over nearly 20 years, and we believe again that the best opportunities for growth and performance from Aussie Home Loans is inside the CFS Group, rather than inside the Commonwealth Bank Group.”

Mr Comyn said that a demerger, rather than a sale, offers a couple of important benefits.

“Firstly, it is a clean and timely exit of all of these businesses,” he said. “I think each of them are good businesses in their own right. We think the best chance for these businesses to perform at their potential, is outside the Commonwealth Bank Group. And CBA shareholders will receive a proportionate interest in the demerged entity, relative to their CBA shareholding. And that enables them to either participate in the growth of the CFS Group over time, or if should they prefer, they can also exit and sell on market.”

While there has been no mention of conflicts of interest or vertical integration in Mr Comyn’s statements about cutting ties with Aussie, there has been plenty of criticism over the bank’s ownership of the brokerage that no doubt weighed on an already heavily saddled CBA.

Representatives from both Aussie and CBA appeared as witnesses during the first round of the Hayne royal commission. Bank ownership of brokerages was also brought up by the Productivity Commission in its draft report on competition in financial services. The PC report concluded that the mortgage broking revolution, which disrupted the major banks in the 1990s, has failed and many brokers now act in the best interest of the banks that own them and not consumers.

“The early 2000s was the last time Australia’s financial system saw a period of fierce competition,” PC chairman Peter Harris said. “If we are to see its like again, we will need a series of policy shift, and a champion to own them.”

CBA’s decision this week may foreshadow some of the policy shifts the PC chairman has suggested, which could see changes to bank ownership of broking businesses. The PC will deliver its final report on Monday.

Meanwhile, it’s business as usual at Aussie Home Loans, according to CEO James Symond.

“Aussie Home Loans confirms CBA Group’s announcement about the planned demerger of its mortgage broking businesses along with its wealth management operations into a new, independent and separately ASX-listed company to be known as [the] CFS Group,” Mr Symond told The Adviser.

“As has been the case since we started, Aussie is committed to providing the best, independent service to our customers, ensuring they get the most suitable home loan tailored to their needs.

“While important in terms of our ultimate ownership, CBA’s announcement will not change this commitment to our customers or have any impact on the service we provide them. As a larger part of a smaller group, this opens greater opportunity for Aussie.”

This week’s announcement is the end of an era for Aussie, which sold its first 20 per cent stake to CBA back in 2008. In August last year, founder John Symond received 2.1 million of CBA shares — worth nearly $164 million — for his remaining 20 per cent stake in the brokerage.

CBA To Demerge Wealth And Mortgage Broking Businesses

In what could be seen a a recognition of the intrinsic conflicts of interest between advice and product manufacturing, CBA has announced that it will demerge its wealth management and mortgage broking businesses. It will also undertake a strategic review of its general insurance business, including a potential sale. No financial details were provided, ahead of the AGM on 8th August.

CBA’s Retail Banking Services (RBS) division will now include Bankwest. In addition, RBS will also include Commonwealth Financial Planning, designed to deliver better customer outcomes through a new safer, simpler, and more scalable model for financial advice. RBS will also have responsibility for General Insurance while the strategic review of that business is underway.

CBA says these initiatives will result in the creation of a leading independent wealth management business and enable CBA to enhance its focus on its core banking businesses in Australia and New Zealand and create a simpler, better bank.

The demerged business, CFS Group, will include CBA’s Colonial First State, Colonial First State Global Asset Management (CFSGAM), Count Financial, Financial Wisdom and Aussie Home Loans businesses.

CFS Group will benefit from a separate listing and ability to pursue its own growth strategies.

CBA says the move will unlock greater value for shareholders through the separation of CBA’s wealth management and banking businesses.

Federal Court Approves AUSTRAC CBA Settlement

Commonwealth Bank of Australia (CBA) notes the approval by the Federal Court today of the agreement between CBA and the Australian Transaction Reports and Analysis Centre (AUSTRAC) to resolve the civil proceedings commenced by AUSTRAC on 3 August 2017.

As noted in CBA’s release on 4 June 2018:

  • CBA will pay a civil penalty of $700 million together with AUSTRAC’s legal costs of $2.5 million.
  • AUSTRAC’s civil proceedings are otherwise dismissed.

CBA will recognise a $700 million expense in its financial statements for the full year ending 30 June 2018, which will be released on 8 August 2018.

Commonwealth Bank’s $700 million fine will end up punishing its customers

From The Conversation.

The Commonwealth Bank of Australia (CBA) this week agreed to pay a record penalty to settle its violations of anti-money laundering and counter-terrorism financing laws. The A$700 million fine plus legal costs will become final upon the approval of the Federal Court.

The deal was met with market approval, and has allowed regulators to claim victory. Given the public’s current hostility to banks in the wake of revelations from the Banking Royal Commission, politicians also joined the bandwagon and applauded CBA’s loss.

What if the penalty is a sign of mob justice, rather than just deserts? And given the scale of the payout, will the fine also end up further punishing customers and shareholders?

Answering these questions requires a close look at the case. CBA was alleged to have violated the Anti-Money Laundering and Counter-Terrorism Financing Act 2006, in several specific ways.

First, it introduced Intelligent Deposit Machines (IDMs) without conducting an independent risk assessment and/or instituting mitigation procedures to tackle money-laundering. Unlike older ATMs, IDMs process cash deposits and make the funds available for transfer immediately. Clearly, criminals could use these features to launder cash gained through crime. CBA wrongly believed that its existing ATM monitoring processes covered these risks.

Second, it was warned about these risks and could have minimised money laundering by imposing daily limits on accounts. CBA refused.

Third, CBA failed to provide transaction reports within 10 business days for cash deposits greater than A$10,000. This violation referred to 53,506 transactions totalling about A$625 million. The failure was due to a coding error – the software was not updated to pick up a new code created for IDM deposits.

Fourth, CBA failed to report transactions with a pattern of money-laundering – apparently misunderstanding its legal obligations.

Fifth, CBA failed to report suspicions about identity fraud – for example, in relation to eight money-laundering syndicates. Therefore, AUSTRAC and law enforcement were unaware of “several million dollars of proceeds of crime mostly connected with drug importation and distribution” that passed into accounts held by CBA.

Sixth, CBA was deficient in monitoring accounts despite warnings from law enforcement – 778,370 accounts were not monitored. CBA was slow to act even after suspicious accounts were terminated, facilitating money-laundering.

Clearly these are significant violations. However, the statement of facts agreed by AUSTRAC and CBA state that the bank did not deliberately or intentionally violate its legal obligations under the relevant laws.

Considering that CBA’s violations were inadvertent, due to technical glitches, and attributable to a mistaken belief about existing systems satisfying legal obligations, the A$700 million fine might be excessive.

International comparisons

By international standards, the fine seems to be very high. This week the UK Financial Conduct Authority fined the British division of India’s Canara Bank £896,100 (A$1.58 million) for “consistent failure” in its money-laundering controls, and for failings “affecting almost all aspects of its business”.

The FCA said the bank’s failings “potentially undermine the integrity of the UK financial system by significantly increasing the risk that Canara could be used for the purposes of domestic and international money laundering, terrorist financing and those seeking to evade taxation or the implementation of sanction requirements”.

In the United States, the Justice Department fined US Bancorp US$528 million (A$694 million) for criminal violations of money-laundering laws and for concealing its behaviour from regulators.

CBA’s fine is far higher than Canara’s punishment for similar violations, and roughly on a par with the sanction meted out to US Bancorp – albeit the latter was for more serious criminal wrongdoing. It is also comparable to the US$665 million (A$874 million) penalty imposed on HSBC (plus US$1.26 billion in sacrificed profits). Unlike CBA, HSBC was punished for “willfully failing” to maintain proper money-laundering controls.

Yet the proceeds from HSBC’s violations stretching back to the 1990s were staggering: at least US$881 million in laundered drug money; a failure to monitor more than US$670 billion in wire transfers and over US$9.4 billion in purchases of physical US dollars from HSBC Mexico; some US$660 million in sanctions-prohibited transactions; and evidence of deliberate sanctions violations by processing transactions to parties in Iran, Cuba, Burma, Sudan, and Libya.

A fair punishment?

The size of CBA’s penalty seems to be more in line with banks that have deliberately flouted money-laundering laws, rather than the smaller punishments handed to banks that did so unintentionally. It is tempting to conclude that this is influenced by the current prevailing mood to “send a message” to financial institutions.

What’s more, we cannot necessarily assume that the fine will act as a deterrent. The penalty is not paid by the CBA staff who acted wrongly; it is paid by the bank, ultimately by the shareholders.

Similarly, the cost of managing enhanced scrutiny and investing in additional compliance machinery will be passed on to customers in the form of higher charges and fees. Likewise, if banks become excessively cautious because of apprehensions about overenforcement, that will impact services and reduce profitability – again harming innocent people.

The punishment must always fit the crime. Excessive punishment is counterproductive and creates additional victims.

If the purpose was really to tackle wrongdoing, the CBA staff who were responsible for the violations should have been identified and penalised.

The A$700 million fine is good for political posturing but will hurt customers and shareholders the most. Bank-bashing has a cost, and it is paid by ordinary people, not politicians.

Author: Sandeep Gopalan, Pro Vice-Chancellor (Academic Innovation) & Professor of Law, Deakin University

CBA moves away from conflicted volume-based service model

From MPA.

CBA has announced changes to its volume-based ‘diamond, gold, silver and bronze’ service model for brokers following advice from the Combined Industry Forum and intense questioning at the royal commission.

During the royal commission hearing on 15 March, Daniel Huggins, CBA’s executive general manager home buying, acknowledged that the bank decided to change the volume-based structure after acknowledging that it could create conflicts of interest with diamond brokers being awarded faster turnaround times and better service.

In a note to MPA on Wednesday, Huggins explained that the new two-tiered system is part of the bank’s “ongoing commitment to support and recognise brokers who are consistently delivering good customer outcomes”.

CBA’s previous model had 11 segments with the top being diamond. Those brokers who qualified had to write at least $15m and/or settle at least 75 CBA loans per year and achieve three out of five quality metrics.

Under the new regime, there will only be two categories: essential and elite.

The model moves away from volume-based requirements, as recommended by the Combined Industry Forum. Instead, a broker’s performance will be assessed on five key quality metrics and five complementary metrics. Their performance will be evaluated on a quarterly basis.

This should help even the playing field for regional brokers who generally have smaller average loan sizes and wouldn’t have made the top tier under CBA’s previous structure.

“We are really pleased to announce a simplified tiered service model with a focus on quality that seeks to recognise and reward our accredited brokers who deliver strong customer outcomes,” Huggins said.

CBA and accreditation

CBA also recently announced that instead of de-accrediting brokers who hadn’t written a loan with the major in 12 months, it would just require them to complete an e-learning training module to ensure they are updated on current products and criteria.

The bank said it will no longer require brokers to write a minimum number of loans to retain accreditation.

In the past, brokers who wanted to maintain CBA accreditation had to submit a minimum of four home loan applications and settle at least three every six months, although according to CBA this was not systematically enforced.

The royal commission revealed that in 2017 CBA revoked the accreditation of 710 brokers due to inactivity.

CBA Settles AUSTRAC Claims

Commonwealth Bank of Australia (CBA) has announced it has entered into an agreement with AUSTRAC, the Australian Government’s financial intelligence agency, to resolve the civil proceedings commenced by AUSTRAC in the Federal Court of Australia on 3 August 2017.

The agreement follows Court-ordered mediation between CBA and AUSTRAC and remains subject to Court approval. As part of the agreement:

  • CBA will pay a civil penalty of $700 million together with AUSTRAC’s legal costs of $2.5 million.
  • CBA has admitted further contraventions of Australia’s Anti-Money Laundering and Counter-Terrorism(AML/CTF) Act, beyond those already admitted, including contraventions in risk procedures, reporting,monitoring and customer due-diligence.
  • AUSTRAC’s civil proceedings are otherwise dismissed.

CBA Chief Executive Officer Matt Comyn said: “This agreement, while it still needs to be approved by the Federal Court, brings certainty to one of the most significant issues we have faced.

“While not deliberate, we fully appreciate the seriousness of the mistakes we made. Our agreement today is a clear acknowledgement of our failures and is an important step towards moving the bank forward. On behalf of Commonwealth Bank, I apologise to the community for letting them down.

“Banks have a critical role to play in combating financial crime and protecting the integrity of the financial system. In reaching this position, we have also agreed with AUSTRAC that we will work closely together based on an open and constructive approach.

“We are committed to build on the significant changes made in recent years as part of a comprehensive program to improve operational risk management and compliance at the bank. To date we have spent over $400 million on systems, processes and people relating to AML/CTF compliance and will continue to prioritise investment in this area.

“We have changed senior leadership in the key roles overseeing financial crimes compliance supported by significant resources and clear accountabilities.

“We have started implementing our response to the recommendations provided to us by our prudential regulator, APRA, to ensure our governance, culture and accountability frameworks and practices meet the high standards expected of us.

“I am also very focused on ensuring we have clear lines of accountability across our entire business. This includes an approach to risk management that recognises the importance of non-financial risks, including an escalation framework that ensures key operational and compliance issues such as these are identified, escalated and resolved in a timely manner.

“These changes are part of a large and concerted effort to become a better, stronger bank – one that earns the trust of our customers, staff, regulators and shareholders. Today is another very important step forward, and continuing to make the changes we need in an open, transparent and timely way is my absolute priority as CBA’s new chief executive,” Mr Comyn said.

CBA provided for an estimated penalty of $375 million in the half year ending 31 December 2017 at which time the bank noted the proceedings were complex and ongoing, and the ultimate penalty determined by the Court may be higher or lower than the amount provided for. CBA will recognise a $700 million provision in its financial statements for the full year ending 30 June 2018 which will be announced on 8 August.

Background

The settlement with AUSTRAC includes a Statement of Agreed Facts and Admissions. A copy of the Statement is attached to this announcement and is available on CBA’s website. In summary, as part of the agreement CBA has admitted to:

  • Late filing of 53,506 Threshold Transaction Reports for cash deposits through Intelligent Deposit Machines (IDMs).
  • Inadequate adherence to risk assessment requirements for IDMs on 14 occasions.
  • Transaction monitoring did not operate as intended in respect of a number of accounts between October 2012 and October 2015.
  • 149 Suspicious Matter Reports were filed late or were not filed as required.
  • Ongoing customer due-diligence requirements were breached in respect of 80 customers.

We appreciate the key role we play in supporting law enforcement to fight financial crime. Our contribution includes:

  • During the period of the claim, we submitted more than 44,000 Suspicious Matter Reports, including 264 SMRs in relation to the syndicates and individuals referred to in AUSTRAC’s claim.
  • We submitted more than 19 million reports to AUSTRAC (including SMRs, TTRs and international fund transfer instructions) during the period covered by the AUSTRAC claim up to the end of 2017. We submitted over 4 million of these reports to AUSTRAC in 2017 alone.
  • We responded to approximately 20,000 law enforcement requests for assistance in 2017.

CBA has made significant progress in strengthening its policies, processes and systems relating to its obligations under the AML/CTF Act through our Program of Action. This is a continuing process of improvement and has already included:

  • Boosting AML/CTF capability and reporting by hiring additional financial crime operations, compliance and risk professionals with more than 300 professionals dedicated to financial crimes operations, compliance and risk across the group.
  • Strengthening Know Your Customer processes with the establishment in 2016 of a specialist hub providing consistent and high-quality on-boarding of customers, at a cost of more than $85 million.
  • Launching an upgraded financial crime technology platform used to monitor accounts and transactions for suspicious activity.
  • Adding new controls such as using enhanced digital electronic customer verification processes to supplement face-to-face identification to reduce the risk of document fraud.
  • Introducing an account based daily limit of $10,000 for cash deposits using IDMs, the first Australian bank to do so.