Tag: COBA

APRA Admits Mortgage Lending Standards Have Deteriorated

APRA Chairman Wayne Byers gave the keynote address at the COBA 2017 – Customer Owned Banking Convention in Brisbane. It included some remarks on the state of play of housing lending standards making the point that until recently, systematically, lending standards were eroding, but this is now being reversed. He specifically mentioned a desire for borrower debt-to-income levels to be appropriately constrained in anticipation of (eventually) rising interest rates.

We would say better late than never!

Earlier this year, we announced further measures to reinforce prudent standards across the industry. We did this because, in our view, risks and practices were still not satisfactorily aligning. We remain in an environment of high house prices, high and rising household indebtedness, low interest rates, and subdued income growth. That environment has existed for quite a few years now, and one might expect a prudent banker to tighten lending standards in the face of higher risk. But for some years standards had, absent regulatory intervention, been drifting the other way. Indeed, if we look back at standards that the industry thought important a decade ago, we see aspects of prudent practice that we are trying to re-establish today.

The erosion in standards has been driven, first and foremost, by the competitive instincts of the banking system. Many housing lenders have been all too tempted to trade-off a marginal level of prudence in favour of a marginal increase in market share. That temptation has, unfortunately, been widespread and not limited to a few isolated institutions – the competitive market pushes towards the lowest common denominator. The measures that we have put in place in recent years have been designed, unapologetically, to temper competition playing out through weak credit underwriting standards.

Since we have been focussing on lending standards, APRA’s approach has been consistently industry-wide: the measures apply to all ADIs, albeit with additional flexibility for smaller, less systemic players around the timing and manner in which they have been expected to adjust practices. There is no reason, however, why poor quality lending should be acceptable for some ADIs and not others, or in one geography and not others. Prudent standards are important for all.

At a macro level, our efforts appear to be having a positive impact. As I have spoken about previously, serviceability assessments have strengthened, investor loan growth has moderated and high loan-to-valuation lending has reduced. New interest-only lending is also on track to reduce below the benchmark that we set earlier this year. Put simply, the quality of lending has improved and risk standards have strengthened.

We would ideally like to start to step back from the degree of intervention we are exercising today. Quantitative benchmarks, such as that on investor lending growth, have served a useful purpose but were always intended as temporary measures. That remains our intent, but for those of you who chafe at the constraint, their removal will require us to be comfortable that the industry’s serviceability standards have been sufficiently improved and – crucially – will be sustained. We will also want to see that borrower debt-to-income levels are being appropriately constrained in anticipation of (eventually) rising interest rates.

These expectations apply across the industry, to large and small alike. Pleasingly, the industry is moving in the right direction to achieve that. Improved serviceability standards are being developed, and policy overrides are being monitored more thoroughly and consistenly. The adoption of positive credit reporting, which APRA strongly endorses, will remove a blind spot in a lender’s ability to see a borrower’s leverage. Coupled with the higher and more risk-sensitive capital requirements that I mentioned earlier, these developents should – all else being equal – provide an environment in which some of our benchmarks are no longer needed. The review of serviceabilitiy standards across the small ADI sector that we are currently undertaking will help inform our judgement as to how close we are to that point.

His comments on the role of mutual ADI’s are are worth reading…

PC Inquiry can address banking competition problems – COBA

The customer owned banking sector today identified significant problems with banking competition in Australia and made three key recommendations to the Productivity Commission (PC) Inquiry to address the issue.

In their submission they highlighted the better rates on offer from Customer-owned banks, reflecting lower returns to stakeholders, but of benefit to customers.  They also show better rates for depositors.

COBA’s Submission to the Productivity Commission Inquiry into Competition in the Australian Financial System recommends:

1. Policymakers and regulators give greater consideration to the impact on competition of the regulatory compliance burden and ensure that regulation is targeted, proportionate, risk-based and, where possible, graduated.

2. The Government introduce an explicit ‘secondary competition objective’ (SCO) into APRA’s legislative mandate, including with an accountability mechanism.

3. Interventions are needed to empower consumers to switch between banking products but interventions to promote switching should be cost-effective and based on rigorous market studies of banking product markets and consumer behaviour.

COBA’s Director – Policy, Luke Lawler, said:

“The enduring solution to concerns about the banking market is action to promote sustainable competition.

“We don’t have sustainable banking competition at the moment. A lack of competition can contribute to inappropriate conduct by firms, and insufficient choice, limited access and poor quality products for consumers.

“The regulatory framework over time has entrenched the dominant position of the largest banks.

“Promoting a more competitive banking market does not require any dilution of financial safety or financial system stability.

“A ‘secondary competition objective’ (SCO) for APRA would raise the relative ‘priority’ of competition compared to APRA’s ‘other considerations’. It would remain secondary to APRA’s primary responsibilities of financial stability and safety. The SCO would include reporting obligations to ensure accountability against the objective.

“The SCO would formalise the relative ‘prioritisation’ of competition and ensure that it becomes ingrained into APRA’s day-to-day regulatory processes.

“APRA’s peer regulator in the UK, the PRA, was given an SCO in 2014 and the outcome is a ‘material change of gear’ where ‘competition is gaining airtime and traction at all levels’ and ‘there are numerous instances where competition considerations have influenced policy outcomes.’

“We do not doubt that APRA already gives some consideration to competition but we judge this to be inadequate and inconsistent.

“Examples of APRA’s failure to give due consideration to competition concerns include: lack of urgency in addressing the market distortions caused by the unfair funding cost advantage enjoyed by the major banks due to the implicit guarantee continuing wide gap in mortgage risk weight settings between the major banks and smaller banking institutions, and implementation of macro-prudential measures affecting investor lending that rewarded major banks which had expanded their investor lending portfolios most aggressively before the cap was applied.

“Customer owned banking institutions offer the full range of consumer retail banking products and services, including highly competitive home loans, credit cards, personal loans and deposit products. Many of these products are market leading and award winning.

“As the providers of these products, customer owned banking institutions strongly support cost-effective measures to empower consumers to switch.

“COBA recommends rigorous market studies of retail banking product markets, taking into account consumer behaviour and behavioural biases, to identify the barriers to switching and to design interventions to reduce these barriers in the most cost-effective way.

“We welcome the Government’s decision to provide resources to the ACCC to establish a dedicated Financial Services Unit to undertake regular in-depth inquiries into competition issues in the financial system. We also support the Government’s decision to include competition in ASIC’s mandate. We recommend clarity of responsibility between these two regulators for carrying out market studies and designing interventions to promote switching.”

COBA statement to Productivity Commission Inquiry into Competition in the Financial System

Mark Degotardi, CEO, Customer Owned Banking Association (COBA) discussed banking competition in a statement to Productivity Commission Inquiry into the State of Competition in the Australian Financial System.

They call out the implicit Government guarantee the major banks enjoy, the differential risk weights, and how the recent 10% investor loan growth speed limit adversely impacted overall banking competition.

Our members are mutual banks, credit unions and building societies.

Customer owned banking institutions have market leading customer satisfaction and highly competitive pricing.

They provide the full range of retail banking products and services, including home loans, credit cards, personal loans, transaction accounts and term deposits.

What they don’t have is a level playing field.

That’s why we welcome this inquiry and we are hopeful it will recommend further action to promote competition and choice in the retail banking market.

Our sector has:

  • 4 million customers
  • total assets of $106 billion
  • around 10 per cent of household deposits
  • around 5 per cent of the home loan market.

We have a strong track record and significant potential to increase competitive pressure and innovation in retail banking but we need a fairer regulatory framework.

We look forward to engaging with this inquiry on improving the regulatory framework and on measures to empower consumers to find the best deal and the best banking services provider.

Items 4 and 5 of this inquiry’s terms of reference concern barriers to competition and potential policy changes to reduce or remove those barriers.

The Government’s position, as noted by the Treasurer in a recent speech to Parliament, is that:

  • the banking sector is an oligopoly and the largest banks have significant pricing power which they have used to the detriment of everyday Australians
  • the banking system is highly concentrated, and
  • major banks benefit from a regulatory system, including mortgage risk weight settings, that has helped embed their dominant position.

There are a number of significant areas that we would encourage the Commission to consider:

  • the impact of the implicit guarantee on competition
  • the regulatory advantage gained by the largest institutions in APRA’s capital framework
  • the need for customer owned ADIs to be able to raise capital to compete more effectively, and
  • the need for APRA to be required to consider competition as an explicit ‘secondary objective’ in addition to its primary objectives of financial safety and stability.

Implicit guarantee

There is now widespread acceptance that the major banks unfairly benefit from an implicit guarantee provided by taxpayers. This implicit guarantee gives the major banks a significant funding cost advantage.

This unfair funding cost advantage is getting worse, with one of the major credit rating agencies recently increasing the benefit that major banks obtain in terms of a credit rating uplift.

This advantage is significant and is far higher than the Government’s recently announced levy on the 5 largest banks.

Risk weights

The major banks are gifted another funding cost advantage by the regulatory framework because they are permitted to calculate their own risk weights for the amount of regulatory capital they hold against mortgages.

This means that major banks hold much less regulatory capital against mortgages compared to their smaller competitors, and this problem is magnified for the highest quality mortgages, i.e. low risk, very low loan-to-valuation mortgages.

So, it is ‘win win’ for the major banks – they hold less capital against loans and pay less for debt.

Capital

Customer owned ADIs raise most of their capital through retained earnings and have limited access to additional forms of capital.  This limits our competitiveness and our ability to make strategic investments in a range of areas including investment in technology.

The Government is currently conducting a separate inquiry process to look at capital raising for mutual and cooperative institutions in Australia and we are working with APRA to develop CET1 capital options for customer owned banking institutions.

If there is genuine commitment to competition, this issue needs to be resolved as a priority.

APRA’s competition objective

Regulators need to give more consideration to the impact on competition of their decisions.

The risk weight settings are a good example, but another example includes APRA’s implementation of its macroprudential crackdown on investor lending.

APRA’s 10 per cent cap on investor lending growth entrenched the major banks’ share of this market and undermined competition. Investor lending made up 40 per cent of major banks’ home loan portfolios, almost double the proportion of our sector.

There is an issue with competition and this decision simply embeds the existing problem.

Our sector has a strong record of prudent lending and we support APRA’s efforts to promote sound lending standards. However, APRA’s blanket investor lending intervention has harmed our sector’s competitive position and enabled the major banks to reprice their investor loan portfolios without fear of losing market share – increasing their profits and further entrenching their dominance.

We think that future problems of this kind could be avoided or minimised if APRA’s legislative mandate was changed to include an explicit “secondary competition objective.”

This would require APRA to think more about the impact on competition in pursuing its primary objectives of financial safety and stability and to be more accountable by reporting annually against the secondary competition objective.

Customer owned banking institutions are nimble and closer to their customers than their larger competitors but they don’t have the same economies of scale to keep costs down.  Our members often used aggregated structures to achieve scale, and are frequently at the forefront of implementing technology innovations for their customers.

However, the costs of regulatory compliance are more difficult to mitigate and involve basic fixed costs that larger entities can spread over a much larger asset base.

Increasing the focus of regulators and policy-makers on the impact of regulatory compliance costs, and minimising those costs where possible, will promote competition.

Open Banking

COBA welcomes the Government’s announcement that it will introduce an open banking regime to increase access to banking product and customer data by consumers and third parties. We support policies that benefit consumers and allow them to find banking products better suited to their needs.

Open banking will allow COBA members to offer new services, like tools for their customers to better manage their finances.

However, if participation in open banking is mandatory and if the implementation timetable is too aggressive, it could harm competition by imposing unacceptable costs on small players – to the detriment of their customers.

The same arguments apply to mandating participation in comprehensive credit reporting and demonstrate why it is critical that competition must be a significant consideration in the determination of the regulatory framework and the process of setting Government policy in banking and financial services in Australia.

Often the promotion of competition is portrayed as a threat to stability.

Those who promote this idea are the institutions that have a vested interest in maintain the banking oligopoly.

Fairer competition and financial stability are complementary aims.  A more diverse banking sector will strengthen the resilience of the system and deliver better outcomes to consumers.

There is a problem with competition in banking – the only question is what we as a community are prepared to do about it.

COBA – Opening Statement Bank Levy Inquiry

COBA’s opening statement focussed on the impact of the implicit guarantee which the large banks enjoy, which they says is distorting the banking market by providing the biggest players with an unfair funding cost advantage. They welcome the major bank levy as a modest step towards reducing this funding cost advantage.

COBA is the industry association for Australia’s customer owned banking institutions – mutual banks, credit unions and building societies.

We have 4 million customers, around 80 institutions across Australia, $106 billion in assets and roughly 10 per cent of the household deposits market.

This Bill is primarily about Budget repair but it is of course intended to contribute to a more level playing field in the banking market.

It comes as no surprise we strongly support measures to promote competition in banking because they are very clearly needed.

There is a big problem with competition in banking in this country.

In his second reading speech, the Treasurer noted that:

  • the banking sector is an oligopoly and that the largest banks have significant pricing power which they have used to the detriment of everyday Australians
  • the banking system is highly concentrated
  • major banks benefit from a regulatory system, including mortgage risk weight settings, that has helped embed their dominant position.

From our perspective, the most important component of the Bill is that it is intended to complement prudential reforms being implemented by the Government and APRA to improve financial system resilience and competition.

We support measures to reduce unfair competitive advantages enjoyed by the major banks.

One of these is the unfair funding cost advantage enjoyed by these banks as a result of the implicit guarantee provided by taxpayers due to the perception that the major banks are ‘too big to fail’.

COBA welcomes the major bank levy as a modest step towards reducing this funding cost advantage.

In relation to the broader prudential reforms being implemented by APRA and the Government, we note that the ‘too big to fail’ problem is the target of Recommendation 3 of the 2014 Financial System Inquiry report.

That recommendation calls for implementation of a framework in line with emerging international practice, to facilitate the orderly resolution of Australian ADIs and minimise taxpayer support.

The Government’s 2015 response has no specific implementation date, but says steps should be taken to reduce any implicit government guarantee and the perception that some banks are too big to fail.

The Government has endorsed APRA as Australia’s prudential regulator to implement this recommendation in line with that international practice.

We acknowledge that the ‘too big to fail’ problem is a very complex problem to solve but we would encourage the Government and APRA to continue to give this issue the highest possible priority.

This is because the ‘too big to fail’ problem tends to get worse over time. The unfair funding cost advantage creates incentives for major banks to become even bigger and more complex.

The 2014 Financial System Inquiry report said perceptions of implicit guarantees have costs, creating distortions in the market.

The report said credit rating agencies explicitly factor in ratings upgrades for banks they perceive to benefit from Government support, directly benefiting those banks. As has been said by previous witnesses, this was worth a two-notch upgrade for the major banks in 2014.

As of last month, at least in relation to one of the rating agencies, Standard & Poor’s, that two-notch upgrade is now three notches.

The implicit guarantee is distorting the banking market by providing the biggest players with an unfair funding cost advantage.

The regulatory framework helps the major banks in other ways.

Compared to major banks, customer owned banks and regional banks have to hold much more regulatory capital against mortgages. This gives the major banks another significant funding cost advantage.

APRA has formally designated the major banks as ‘systemically important’ and applied a capital surcharge on them of 1 per cent.

But this surcharge is right at the bottom end of the international spectrum of such capital surcharges, which range up to 6 per cent in some cases.

We have a banking market where major banks benefit from unfair regulatory capital settings and a subsidy from taxpayers.

The major bank levy is a modest but welcome step toward a more level playing field in banking.

So from our point of view, we look forward to APRA and the Government working on the broader prudential reform agenda to promote competition and resilience in the banking market.

Consumers stand to gain from a more competitive banking market where all competitors have a fair go.

New campaign to check out banking competition

COBA has upped the ante on banking competition with the launch of a new campaign to raise awareness of alternatives to the big four. Consumers who shop around may well find better deals, but the process of switching banks is still fraught with difficulty. COBA should be lobbying for account number portability, as this would break the nexus and make switching more likely. If mobile phone numbers can be portable, why not bank accounts?

A new campaign begins today to encourage Australians to check out the banking alternatives available to them, including Australia’s mutual banks, credit unions and building societies.

“The current banking debate has started the conversation about alternatives to the big 4,” COBA CEO Mark Degotardi said.

“There are 80 mutual banks, credit unions and building societies that offer a strong and safe alternative and who already serve 4 million Australian customers.

“These customer-owned banking institutions offer home loans, credit cards and everyday banking accounts.

“Customer owned banking has $104 billion in assets and invests healthy profits back into the community and into investment in better products and services.

“We encourage Australians to visit our Check Out the Competition website to learn more about the customer owned banking alternative.”

Customer owned mutual banks, credit unions and building societies:

o    Are all Authorised Deposit-taking Institutions (ADIs), just like the big 4.

o    Bring a fundamentally different model to the market, a model where customer interests always comes first.

o    Have market-leading customer satisfaction ratings, highly competitive pricing and community focus.

“We hope Australians will check out the competition and like what they see.

Bank Switching Is A Pain

According to the Customer Owned Banking Association, Australians are willing to switch home loans but believe the process is too painful, there’s too much paperwork and it’s not worth the effort.

These are some of the key findings of a national poll of 1000 Australians by BLACKMARKET Research on what drives competition in the banking market.

“This poll shows Australians want competitive home loans, but they’re being let down by the switching system,” COBA CEO Mark Degotardi said.

“Polls like this tell us there’s a problem – people want to switch but find it too hard to do so, so they simply give up. That’s not genuine banking competition.

“We believe one of the reasons is the amount of time between a consumer asking to switch and their current home loan provider completing the paperwork.

“All stakeholders need to have a closer look at this issue to see if switching can become more efficient.

“If people want to switch from a major bank to a customer owned banking institution, we find it hard to understand in 2017 how it can take up to three months in some cases.”

The BLACKMARKET Research poll of 1000 Australians found:

  • 36% of people say are they are fairly/very likely to change home loans in the next 12 months
  • More than one-third of people say they haven’t switched because the process is painful
  • One in five gave the reason of paperwork or it not being worth the effort for not switching

The poll also found many customers were happy with their current provider, including four out of five customer owned banking customers.

“Customer owned banking is doing well, with market leading customer satisfaction and net promoter score ratings,” Mr Degotardi said.

“Part of the reason is our highly competitive and award winning products, including our home loans that have average standard variable home loan rates 0.64%* lower than the big four banks.

“If consumers shop around they will see there’s real value in switching to a customer owned alternative.”

*14 February, 2017: Comparison calculated using data sourced from the Canstar Online Database for standard variable rate products, which are available to owner occupiers borrowing $400,000 at an 80% LVR. Package, basic, and introductory rates are excluded.

Federal Budget action needed on banking competition

The Customer Owned Banking Association (COBA) – the industry body for credit unions, building societies, mutual banks and friendly societies –  has today called on the Turnbull Government to allocate funds in the May Budget to bring forward a planned Productivity Commission review of banking competition.

“There is an urgent need for well-considered measures to promote competition in banking,” COBA CEO Mark Degotardi said.

“In its response to the 2014 Financial System Inquiry (FSI), the Government agreed to implement periodic reviews of competition in the financial sector.

“COBA requests allocation of funding to enable the Productivity Commission to complete the first such review by the end of 2017. The Government’s current commitment is to commence, but not complete, such a review in 2017. Given the state of competition in the banking market, we can’t afford to wait.

“The case for an accelerated timetable for the Productivity Commission review is underlined by the House Economics Committee’s November 2016 report that was highly critical of the state of competition in the banking market.”

The House Economics Committee report found:

  • Australia’s banking sector is an oligopoly
  • Australia’s four major banks have significant pricing power, higher than average returns on equity and large market shares

A lack of competition in Australia’s banking sector has significant adverse consequences for the Australian economy and consumers. It:

o    creates issues around banks being perceived as too-big-to-fail (TBTF) (such as moral hazard)

o    reduces incentives for the major banks to innovate and invest in new infrastructure, and

o    can allow banks to use their pricing power to extract excess profits from consumers.

“The enduring solution to concerns about the banking market is action to promote sustainable competition so that poor conduct is swiftly punished by loss of market share.

“An expert review to identify the barriers to a more competitive market and measures to overcome those barriers is sorely needed,” Degotardi said

“COBA’s recently commissioned Deloitte Access Economics (DAE) report on implementation of key FSI recommendations shows that significant work remains unfinished.

“We strongly endorse DAE’s suggestion that the Productivity Commission review should consider whether regulators’ rules and procedures are creating inappropriate barriers to competition and whether there is appropriate regard to other business models, including the customer owned model.”

The DAE report mentions two examples of regulator decision-making affecting competition:

  • APRA’s approach to regulatory capital instruments for customer owned banking institutions, and
  • APRA’s application of the cap on investor lending growth.

COBA’s pre-budget submission lodged with Treasury urges the Government to announce the following measures in the 2017-18 Budget:

1.    Funding to bring forward a review by the Productivity Commission of competition in the banking market, to report by the end of 2017.

2.    A company tax rate for customer-owned banking institutions that matches the effective tax rate of major banks of between 22% and 25%.

3.    Expand GST RITC item 16 ‘credit union services’ to accommodate mutual building societies and mutual banks that are former mutual building societies.

“These measures, along with implementation of key FSI recommendations, will help deliver a more competitive banking market for the benefit of consumers and the wider economy.”

Banking reform report card: ‘could do better’

A new report from Deloitte Access Economics has highlighted significant work remains on implementing key recommendations of the Financial System Inquiry (FSI).

The Customer Owned Banking Association (COBA) commissioned the report on implementation of FSI recommendations 1, 2, 3 & 30 because it is now more than two years since the report was delivered to Government and more than one year since the Government announced its response.

The Customer Owned Banking Association (COBA) engaged Deloitte Access Economics to report on progress in implementing the following recommendations of the 2014 Financial System (Murray) Inquiry (FSI):

  • Recommendation 1: Set capital standards such that Australian authorised deposit-taking institution capital ratios are unquestionably strong.

  • Recommendation 2: Raise the average internal-ratings-based (IRB) mortgage risk weight to narrow the difference between average mortgage risk weights for authorised deposit-taking institutions using IRB risk-weight models and those using standardised risk weights.
  • Recommendation 3: Implement a framework for minimum loss absorbing and recapitalisation capacity in line with emerging international practices, sufficient to facilitate the orderly resolution of Australian authorised deposit-taking institutions (ADIs) and minimise taxpayer support.
  •  Recommendation 30: Review the state of competition in the sector every three years, improve reporting of how regulators balance competition against their core objectives, identify barriers to cross-border provision of financial services and include consideration of competition in the Australian Securities and Investments Commission’s (ASIC) mandate.

Deloitte Access Economics finds that delays to implementation of the recommendations would adversely affect the ability of the financial system to realise the benefits of these reforms. These benefits were identified by the FSI as helping to:

  • ensure the robustness of the financial system
  • aid competition in the banking sector
  • address the ‘too big to fail’ issue in the banking sector.

“The customer owned banking sector wants to see more urgency from government and regulators in implementing the key FSI reforms,” COBA CEO Mark Degotardi said.

“This report is timely because the House of Representatives Economics Committee has just found that Australia’s banking market is an oligopoly where the major banks have significant market power that they use to the detriment of consumers.

“The House Economics Committee found that a lack of competition in banking has significant adverse consequences for the economy and consumers.

“There is no time to waste, yet Deloitte Access Economics’ report card finds only limited progress on the key FSI recommendations.

“In relation to the Recommendation 30 requirement for regulators to explain how they balance competition with their other mandates, Deloitte Access Economics finds that there has been ‘little progress’.

“This is particularly disappointing because regulator decision-making can have a significant impact on competition. Deloitte Access Economics mentions two examples of this: APRA’s approach to regulatory capital instruments for customer owned banking institutions and APRA’s application of the cap on investor lending growth.

“Deloitte Access Economics’ report proposes a draft terms of reference for a Productivity Commission review of competition in the financial system, focusing on the banking sector.

“COBA welcomes Deloitte Access Economics’ suggestion the PC review should consider whether regulators’ rules and procedures are creating inappropriate barriers to competition and whether there is appropriate regard to other business models, including the customer owned model.”

Deloitte Access Economics has provided the following snapshot of the status of key FSI recommendations:

Table 1.1: Overall state of play

 

State of play
Recommendation 1

Capital levels

 Some progress, yet to be completed.

·         Steps already taken which have seen an increase in the capital ratios of the Australian major banks.

·         Current schedule suggests that implementation may be completed in 2018.
Recommendation 2

Narrow mortgage risk weight differences

 Some progress, yet to be completed.

·         Still in progress, although interim steps have been taken to narrow risk weights.

·         Current schedule suggests that implementation may be completed in 2018.
Recommendation 3

Loss absorbing and recapitalisation capacity

 Limited domestic progress; contingent on international developments.

·         No set timeframe, but progress is expected to “hasten slowly”.
Recommendation 30

Strengthening the focus on competition in the financial system

 Limited progress.

·         Current schedule suggests that implementation could be completed by end-2017.

Source: Deloitte Access Economics