Enforcing the Code

The Customer Owned Banking Code of Practice is administered by the Code Compliance Committee. We are an independent Committee established by the Customer Owned Banking Association (COBA).

Our Charter

Our Charter governs our relationship with the COBA Board and sets out our responsibilities. These include monitoring and reporting on compliance with the Code and determining Code breach allegations that have been referred to us.

Our Charter, together with the Code, sets out the terms under which we operate.

Download the Code Compliance Committee Charter (PDF, 373 KB, 23 pages)


Under our Charter, we may impose sanctions on a Code Subscriber. These include:

  • Issuing a formal warning.
  • Requiring the Code Subscriber to train its staff on the Code.
  • Requiring the Code Subscriber to place corrective advertising.
  • Publicly naming the Code Subscriber as non-compliant with the Code.
  • Advising COBA of the Code Subscriber’s non-compliant status, and/or failure to undertake a required course of action.

We may only impose a sanction on a Code Subscriber if we are satisfied that the Code Subscriber:

  • Is guilty of serious or systemic non-compliance with the Code.
  • Has ignored a request from us to remedy a breach of the Code or has failed to remedy that breach within a reasonable time.
  • Has breached an undertaking given to us.
  • Has not taken reasonable steps to prevent a breach of the Code from continuing to occur or reoccurring after having been warned by us that a sanction might be imposed.

The following diagram summaries the actions we may take in enforcing Code obligations:


Find our more

Classification of noncompliance (PDF, 1MB, one page)

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