Welcome to the website of the Independent Review of the Customer Owned Banking Code of Practice (‘COBCOP’). This review is being conducted at the request of the Customer Owned Banking Association (COBA) by Phil Khoury of cameron. ralph. khoury. The review is due to be completed in the second half of 2019.
This website will be maintained and updated throughout the review to keep interested stakeholders informed about the review progress, to invite public input about the COBCOP and to publish written submissions made to the review about its operation.
Report Four – 27th December 2019
We now attach our final report as independent reviewers of the COBCOP – Report Four. This report addresses the final round of comments received from stakeholders. As for the earlier reports, this should be read in concert with the first Three reports.
Click here to download Report Four
We have also provided indicative Code drafting which builds upon the drafting that we produced with our earlier reports but has been substantially revised to take account of stakeholder comments. This draft is only intended to provide stakeholders with the intent of our recommendations. It has not yet been re-drafted for plain English or for efficiency and consistency.
Click here to download the Draft Code.
This concludes our role as independent reviewer. As set out in our report, it is now for COBA to review our recommendations and indicative drafting and decide how much of our work it wants to adopt and what process it wants to adopt going forward. Once COBA has decided on the provisions of the new Code, there will of course need to be a detailed process to review, test and refine the drafting we have put forward.
We would also like to express our gratitude to the stakeholders who contributed enormously to this review with their very helpful comments, explanations and suggestions.
Responses to Review Report Three – 4th November 2019
The Reviewers have now received written responses to Report Three, which are now available as Public Submissions. Click here to view these submissions
Responses to Review Report Two – 14th October 2019
The Reviewers have now received written responses to Report Two, which are now available as Public Submissions. Click here to view these submissions.
Review Report Three Released – 1st October 2019
Click here to download Report Three
The independent Reviewers have now released Report Three – which addresses Code monitoring and compliance for the new Code (Part E in the current Code). The Report explains the proposed changes, and includes two attachments – the first an initial drafting of the proposed new Part C and the second a table comparing the proposed new Part C with the ABA 2019 Code.
The proposed Part C is intended to operate along with a separate Charter document (not yet drafted) covering the internal and administrative arrangements for the Code Compliance Committee.
Please note that the initial drafting is intended to convey the intent of the proposed changes and will be revisited once stakeholder feedback has been received.
Feedback from stakeholders is welcome – by phone or email – and requested by October 31st .
Responses to Review Report One – 11th September 2019
The Reviewers have received three written responses to Report One, which are now available as Public Submissions. Click here to view these submissions.
Review Report Two Released – 26th August 2019
Click here to download Report Two
The independent Reviewers have released Report Two – which follows on from Report One and addresses the detailed requirements of the Code under a proposed new Part B. The Report explains the proposed changes, and includes two attachments – the first an initial drafting of the proposed new Part B and the second a table comparing the proposed new Part B with the ABA 2019 Code.
Please note that the initial drafting is intended to convey the intent of the proposed changes and will be revisited once stakeholder feedback has been received.
Feedback from stakeholders is welcome – by phone or email – and requested by October 14th. For those who are interested, a marked-up version of the proposed new Part B is also provided below – showing the comparison with the current Code’s Part D.
Click here to download a marked-up version of the proposed Part B
Review Report One Released – 6th August 2019
Click here to download Report One
The purpose of this first report is to provide an update on the progress of the Review, an explanation of the intended Review process from here and our recommendations about some foundational issues for the Review project. Our aim is to provide transparency to all stakeholders and to provide an opportunity for participation in a timely fashion, so that all stakeholders can help shape our thinking as our ideas develop.
This first report will be distributed to all those who have made submissions to the Review and can be downloaded by clicking the link above. Whilst the Report does not pose specific questions for response, we would welcome any input, either by phone or email.
Feedback is requested by 26 August 2019.
Phil Khoury
Tel: 03 9421 3111
Email: cobcop.review@crkhoury.com
For more detailed information about the review, including the terms of reference and our reports, please go to our About the Review page.