This joint submission responds to the Interim Report of the Independent Review of the Customer Owned Banking Code of Practice and reflects the experience of organisations working directly with people navigating hardship, vulnerability, and barriers to fair banking. It supports the overall direction of reform, including stronger drafting, improved hardship protections, better recognition of vulnerability, dedicated protections for people affected by domestic and family violence, stronger First Nations banking measures, and greater transparency around digital banking and AI.

At the same time, the submission argues that the final report should be more ambitious. It calls for the revised Code to seek ASIC approval, retain enforceable protections within the Code itself, strengthen oversight and consequences for non-compliance, require internal customer advocates across all lenders, improve access to in-person and non-digital banking, expand low-fee and no-fee banking protections, and ensure the compliance committee has the transparency and resourcing needed to do its job effectively.

This is a strong joint effort, backed by a wide range of consumer and community organisations:

• CARE.
• CHOICE.
• Consumer Action Law Centre.
• Consumer Credit Legal Service Western Australia.
• Consumers Federation of Australia.
• COTA Australia.
• Each.
• Financial Counselling Association WA.
• Financial Counselling Australia.
• Financial Counselling Victoria.
• Financial Rights Legal Centre.
• ICAN.
• Mob Strong Debt Help.
• Mortgage Stress Victoria.
• SAFCA.
• Thriving Communities Australia.