With the 2019 Annual Compliance Statement (ACS) program about to roll out, we urge subscribers to the Customer Owned Banking Code of Practice (the Code) to acquaint themselves with changes to this year’s ACS and to utilise this return as a Code compliance annual health check.
The ACS collects complaint and breach information as well as examples of good industry practice. Along with the number and severity of complaints and breaches raised, how a Code subscriber responds reflects their overall level of Code compliance.
The program is also the monitoring cornerstone for the independent Customer Owned Banking Code Compliance Committee (the Committee), helping us to benchmark compliance with the Code, to spot current and emerging issues that we share with industry and the wider community, and to prioritise areas for future reviews.
Information about the ACS and a sample statement has been emailed to Code subscribers at the start of June. The link and password for completion via the online portal will be emailed in mid-June. The completed statement is due 31 August. Please note these dates and ensure the right staff are in place and ready to respond.
Although many elements stay the same year to year, the ACS is not a static document. Developed in consultation with a number of Code subscribers and the Customer Owned Banking Association (COBA), the ACS program responds to changing times by continually refining its process and addressing specific concerns. As a result, the 2019 statement contains changes in the type and breadth of data sought, and an entirely new section on Privacy.
Last year’s ACS saw the introduction of the Breach Data Detail report. The 2018 data helped us to identify a number of industry-wide problem areas, their root causes and – supported by supplementary research conducted by the Committee – to share our findings and suggest improvements.
The 2019 ACS contains other minor changes. These include new categories for institutions, requesting timeframes for remediation actions and separating transaction complaints from pure ATM issues.
The self-reporting of complaint and breach data remains a significant component of the ACS. An essential starting point is ensuring a clear understanding of the definition of ‘complaint’ and ‘Code breach’. A ‘complaint’ is whenever a customer voices dissatisfaction with regard to the provision of a financial product or service. ‘Code breaches’ are ‘complaints’ that can be directly tied to and recorded against, a particular key promise or obligation of the Code.
Providing detailed responses helps you to fully measure your Code compliance health. We encourage you to complete your 2019 ACS with a spirit of self-improvement and we welcome your input into future statements.
If you would like assistance in completing your ACS or would like to become involved in developing future questionnaires, please contact the Committee on [email protected].