This joint consumer submission to the Independent Review of the Customer Owned Banking Code of Practice brings together national consumer policy, legal and frontline financial counselling expertise to assess whether the Code delivers meaningful protections in practice. Strongly informed by extensive casework and feedback from financial counsellors supporting people experiencing financial hardship, vulnerability, domestic and family violence, disaster impacts, incarceration and small business financial stress, the submission highlights where the current Code falls short and how these gaps result in real consumer harm. It calls for clearer, enforceable obligations that go beyond aspirational promises, align with contemporary best‑practice standards, and ensure customer‑owned banks provide accessible, fair and accountable services to people who rely on them most.

This is a joint consumer submission developed collaboratively by the following organisations, with coordination led by Mortgage Stress Victoria and informed by national and jurisdictional financial counselling practice:

• Consumer Action Law Centre
• Consumer Credit Legal Service Western Australia
• Consumer Policy Research Centre
• Consumers Federation of Australia
• Each
• Financial Counselling Australia
• Financial Counselling Victoria
• Indigenous Consumer Assistance Network (ICAN)
• Mob Strong Debt Help
• Mortgage Stress Victoria
• Thriving Communities Australia
• Vacro