CQIB
What does AUSTRAC stand for?
a. Australian Transaction Reports and Analysis Centre
What are the 3 elements included in payment systems:
a. Consumer payment methods, Payment Systems Funds Transfer System, Clearing & settlement systems
Which of the following loan types is regulated under the National Consumer Credit Protection Act 2009?
a.A personal loan entered into between a bank and an individual in 2016 b.A short term loan of 45 days. c.A commercial loan entered into between a bank and an incorporated company in 2020 d.A personal loan arrangement between a sister and a brother transacted in 2012
What is underwriting?
the process by which an insurer determines whether or not, and what basis, to accept a particular risk
what are the 3 forms of consequentialism?
•Ethical Egoism •Ethical Altruism •Utilitarianism
What sits under Microeconomics
Taxes and regulation created by governments Supply and demand and other forces that impact price levels
Which is the decision-making process of framing?
To remove the 'noise' from an issue to allow us to see the problem for what it is
what is operational risk?
The risk of loss resulting from inadequate or failed internal processes, people and systems and from external events - human error, fraud, fire and flood.
what is credit risk?
The risk that a loan will not be repaid, either by full or in part.
What is credit risk?
The risk that an obligation will not be repaid.
What is regulatory risk?
The risk that arises from the failure of a person or entity to comply with legal obligations.
What are the emerging trends in the financial Services market?
-AI and robotics -FinTech's -Crypto currency -Blockchain and bitcoin -Big data -Data analytics
Competition and Consumer Act 2010 covers what areas?
-Anti-competitive conduct (e.g. deliberate conduct to lessen competition) -Cartels (e.g. price fixing, controlling market share, restricting supply) -Collective bargaining and boycotts (e.g. price fixing, restricting supply) -Exclusive dealing -Misuse of market power
What are some commonly used consumer payment methods?
-Cash payments -Non-cash payments (e.g. EFTPOS) -Cheques and other paper-based instruments -Electronic credit transfers and direct debits -Payment cards, e.g. credit and debit cards -ATMs -Third party bill payments (e.g. BPAY) -Internet payment systems (e.g. PayPal)
what is FIDUCIARY DUTY?
A fiduciary is a person who holds a legal or ethical relationship of trust with one or more parties. Typically, a fiduciary duty relates to the care of money or other assets for another person.
Which regulator provides the regulatory sandbox to support the development of financial products and services?
ASIC
Which regulatory body is responsible for enforcing the principles of the National Credit Code?
ASIC
Who provides the licence to ASIC
ASIC
Who regulates NCCP?
ASIC
___ has licenced NAB to provide financial services and act as a consumer credit provider.
ASIC
Which regulator provides regulatory guidance on various aspects of corporate governance?
ASIC - the guidelines define the obligations of company directors and officers
What is profitability?
Ability to generate earnings compared to its expenses and other relevant costs incurred during a specific period of time, ROA and ROE are common metrics
What are acceptable purposes for a consumer loan? What are unacceptable purposes?
Acceptable: Buying a house, purchasing shares, home renovations, construction of a new property Unacceptable: Commercial reasons, gambling, purchase of crown land, time-share properties, purchase of large rural properties, undertaking unlawful activities, commercial reasons (for a consumer loan)
what is the OAIC Financial system regulation responsibilities?
Administers the Privacy Act 1988 (Cth) and related legislation that ensures protection of personal information
What is Annuity?
An investment product through which a cash sum invested provides a regular (usually fixed) income for life, (irrespective of how long the annuitant lives) or a financial term specified at commencement.
what is exchange traded market ?
Are organised and traded on a physical or electronic exchange facility, typically with business rules that define relationships, products and conventions (e.g. the ASX)
What are the first 5 steps of the effective risk management process?
Establish the context, identify the risk, analyse the risk, evaluate the risk, risk treatment
The Reserve Bank of Australia (RBA) became the Australian central bank and banknote issuing authority in:
January 1960
The General Insurance Code of Practice covers many aspects of a customer's relationship with their insurer. When is the latest version effective from, what month year?
July 2020
Which is NOT an essential quality in a good security
Size of land
what is compliance risk?
That of legal or regulatory sanction, and or financial or reputational loss, arising from a bank's or financial institutions failure to abide by the compliance obligations required by legislation, regulation, rules, standards or code of conduct .
What is AML/CTF Act 2008
The Anti-Money-Laundering and Counter Terrorism Financing Act covers the financial sector, gambling sector, bullion dealers and other professionals or businesses that provide services covered by the Act. The AML/CTF Act is part of a legislative package which brings Australia into line with international best practice to deter money laundering and terrorism financing.
What does ACCC stand for and what does it do?
The Australian Competition and Consumer Commission (ACCC) is an independent authority of the Australian government. Its mandate is to protect consumer rights, business rights and obligations, perform industry regulation and price monitoring and prevent illegal anti-competitive behaviour.
What does ACL stand for?
The Australian Consumer Law (ACL) includes areas such as consumer rights when buying goods and services, contracts and unsolicited consumer agreements covering door to door sales and telephone sales. It is administered by the ACCC.
Who is AFCA?
The Australian Financial Complaints Authority (AFCA) is scheduled to be introduced from July 2018 and designed as a one-stop-shop dispute resolution scheme that will replace the SCT, CIO and FOS
What is AFSL?
The Australian Financial Services Licence (AFSL) is the licence required to provide financial advice legally. Any organisation (or person), including super funds, can't provide financial advice unless it holds an AFSL.
What does AUSTRAC stand for and what does it protect?
The Australian Transaction Reports and Analysis Centre administers the Anti-Money Laundering and Counter-Terrorism Financing Act with the aim to keep Australia safe from financial and other serious crime.
What is solvency
The ability of a bank to meet its long term financial obligations and continue operations for the foreseeable future
True or False, Ethics is not the same as compliance?
True
What is monetary policy?
Under the responsibility of the RBA, monetary policy involves setting the interest rate on overnight loans in the money market (cash rate), which in turn influences other interest rates in the economy.
Loans are generally used in which phase of the money laundering cycle?
layering
Moving, dispersing or disguising illegal funds or assets to conceal true origin is which part of the money laundering cycle?
layering
Which type of risk does the following statement describe: "the potential inability of a bank to meet its payment obligations in a timely and cost-effective manner."
liquidity risk
Examples of non-regulated loans:
a) Insurance premiums paid by instalments. b) Credit provided without prior agreement. c) Loans between friends and family.
In 2016 the Australian Bankers' Association released guiding principles for banks that have been designed to improve protections for whistle-blowers. These principles are:
a. Banks are to provide clear guidelines on the reporting and investigation process b. Bank executives need to demonstrate strong and visible leadership c. Bank whistle-blower policies must allow for disclosures on a range of issues from a range of people who have a connection with the bank
What are the three common approaches to ethical issues?
a. Consequentialism, Deontology, Virtue
Can you name some of the Wealth management products?
allocated pensions, managed funds and superannuation, anniuty and investment bonds
A _______ is a legally binding or valid agreement between two parties.
contract
ADI what financial institutions is part of it?
building society and credit unions
what are the 3 common approaches to ethical issues?
consequentialism deontology virtue
is it correct that the duty of the customer is to disclose forgery and to exercise reasonable care drawing cheques?
correct
What are the 3 risks that Banks take so they are able to satisfy cash flow needs? Can you describe any of these?
credit risk, liquidity risk, interest rate risk.
The difference between the interest rates banks pay for deposits and the rates charged on loans is known as what?
the spread
What are the elements required for the law to consider a contract valid?
•1. Offer and acceptance •2. An intention between the parties to create binding relations. •3. Consideration to be paid for the promise made. •4. Legal capacity of the parties to act. •5. Genuine consent of the parties. •6. Legality of the agreement.
An example of the better banking program
whistle blower protection policies and complaint resolution
What are the two main sources of law?
•1. Statute Law - developed by Government •2. Common Law - relied on precent, previous decision making
Which Investment Banking service can often be a fast track option due to lower regulatory requirements?
private placements
"When recording all information about a particular ethical dilemma, it's essential to critically analyse the value judgements being made by each person involved as they record their version of events." - is this recognise or facts?
recognise
what is situation awareness?
recognition that judgement may be affected by a situation factors
In which step of the 5 Ethical dilemmas process would you implement your chosen action?
step 4
Tap and Go' is an easy way to make payments under which amount?
200
What is the term considered for a long-term loan?
Up to 30 years
Life cycles. Who is the key target for banks?
Youths
The Corporations Act 2001 defines all clients as "retail" unless they are?
- PRODUCT VALUE Exceeding $500,000 (excl. where investment comes from risk-based products or superannuation) - INDIVIDUAL WEALTH Net assets of at least 2.5 million, or Gross income for each of the last two years of at least 250,000 - LARGE BUSINESSES Product to be used in connection with a large business (greater than 20 employees, OR 100 if it includes manufacture of goods) - PROFESSIONAL INVESTOR A range of investors (e.g. AFSL holders, body registered by APRA, listed entity and related body corporates) - SOPHISTICATED INVESTOR The AFSL holder has determined to be experienced in using financial services (includes written acknowledgment)
There are two relevant pieces of legislation for ASIC?
- The Financial Services Reform Act (FSRA) - Sets out the laws dealing with business entities in Australia at both federal and interstate levels. - Corporations Act (2001) - Inserted a new Chapter into the Corporations Act 2001 - introducing a single licence regime, and a consistent and comparable disclosure regime, for all financial products.
Define two common ethical perspectives:
-MORAL ABSOLUTISM: Where there is a universal moral principle where everyone's actions are judged -MORAL RELATIVISM: the opposite. There is not always a right answer.
What are the risks addressed in with basel 2 (2007)
. Credit Risk 2. Market Risk 3. Operational Risk
What is the percentage of consumer payments made by cheques (as at 2019?)
0.2%
In which situations can a bank refuse to honour cheques?
1. A garnishee order is received 2. The drawer of the cheque declares bankruptcy
Prior to giving general advice you must provide the customer with:
1. A general advice warning 2. The current version of your Financial Services Guide (FSG)
The Financial Services Industry has five main regulators, who are they?
1. ASIC - corporations act 2001 / FSR act 2001 2. ACCC - competition and consumer act 2010 3. APRA - Australian Prudential Regulation Authority Act 1998 4. RBA - Reserve Bank Act 1959 5. AUSTRAC - Anti Money Laundering and Counter-Terrorism Financing Act
What is the Role of Banks?
1. Act as a financial intermediary between savers and borrowers which results in efficient use of pooled funds 2. Facilitates the creation of money be expanding the supply of money through deposits and loan transactions 3. Creates financial products that benefits its customers
5 functions of bank
1. Acts as a financial intermediary between savers and borrowers 2. Facilitates the creation of money by expanding the supply of money through deposit and loan transactions 3. Creates financial products and services that benefit customers 4. Develops mechanisms for transferring money and making payments 5. Contributes to the development of the economy
Who is NOT a price taker
1. Banks and NBFI's 2. Brokers who act as intermediaries
year of the four pillars
1990
What are the risks addressed in with basel 3 (2010 on wards)
1. Credit 2. Market 3. Operational 4. Liquidity Risk
What are the risks addressed in with basel 1 (1988)
1. Credit Risk
The Competition and Consumer Act (2010) covers anti-competitive behaviour in which of the following areas:
1. Exclusive dealing 2. Collective bargaining
What are the two primary things that council of financial risk council are responsible for?
1. Macro prudential risk. The extent that the fragility of a bank and other financial institutions could affect the market and economy as a whole 2. Regulatory risk - changes in regulation have a significant impact on the activities of financial institutions, potentially causing disruption that may lead to increased compliance and operational costs.
What is the role of the Reserve Bank of Australia (RBA)?
1. Overall stability of the financial system and regulation of the payments system 2. Monetary policy
In the second line of defence, the Risk and Control Functions include:
1. Provide guidance and direction 2. Review and challenge risk management processes
what are the five steps of ethical dilemas
1. Recognise (gather facts, what are the facts) 2. Facts (have all the facts) 3. Discuss 4. Act 5. Review
What is good security?
1. Simplicity of ownership - The lender must ensure the title of security is free of all liabilities which might prevent future action they want to take regarding that security 2. Stability of value - The lender must be able to rely on the value of the security The margin - ensuring the difference between the loan amount and value of the security is sufficient to allow for any volatility in value that may reduce the value Holding value - the value of the asset should not fall below the amount of the borrowing (e.g. securities such as managed funds or ASX shares are more difficult to value as they are subject to sudden or wide fluctuations) 3. Saleability or STRONG realisation - Situations where a borrower is not able to make their agreed repayments a bank may have to 'cash in' or sell (Realise) the security held.
Risk can be classified into two categories. What are they and can you describe them?
1. Speculative Risk- the possibility of a loss or a gain based on a decision to accept or decline a risk 2. Absolute Risk -a situation where there is either a chance of loss or no loss. But there is no chance to gain.
How banks operate
1. accepting deposits 2. granting loans 3. facilitating payments
What are the six Principles for Responsible Banking?
1. alignment 2 impact and target setting, 3. client & customers, 4. stakeholders. 5. governance and culture 6. transparency & accountability
What is an algorithm? What are the two things needed to build an algorithm?
1. historical data 2. definition of success.
what are the two ways that banks make money
1. lending money At rates higher than they pay for deposits. the difference is the spread or the net interest income. when the banks earning assets divid that net interest income, it is the net interest margin 2. charging fees.
What are the four Pillars of FIDUCIARY DUTY?
1. principle 2 process 3 prudence 4 consistency
what are the common themes of code of conduct?
1. trustworthiness 2. respect 3. responsibility 4. fairness (Due process, impartiality and social equity) 5. caring 6. citizenship (Obeying laws, complying with policies and rules, and protecting the environment)
What are the different types of banking?
1.Commercial and retail banking 2.Investment banking 3.Insurance 4.Funds management
What are the additional regulatory requirements that APRA enforces?
1.Limit the flow of new interest only lending to 30% 2.Manage lending to investors to comfortably remain below the legislative benchmark of 10% growth 3.Review and ensure serviceability metrics including interest rate and net income buffers are set at appropriate levels Continue to restrain lending growth in higher risk segments of the overall lending portfolio (e.g. high LVR)
When algorithms make decisions, who can we hold accountable?
1.MORAL AGENCY: A "being" who has the ability to discern right from wrong and make a considered judgement based on professional experience, seek further information or gain a second opinion 2.MORAL RESPONSIBILITY: We are morally responsible if: a)We are causally responsible for the effects or lack of effects of our actions or inactions b)We intentionally brought about the effects or could have foreseen them; and c)The effects are morally important
What are the 3 steps of a loan assessment? (Think about the income principles)
1.Make reasonable enquiries (e.g. income, assets, liabilities) 2.Verity financial situation (e.g. recency of documentation, benchmarking) Make a preliminary assessment - testing criteria that will make the loan not unsuitable
What are the 6 key underlining principles for the financial services industry from the royal commission?
1.Obey the law 2.Do not mislead or deceive 3.Act fairly 4.Provide services that are fit for purpose 5.Deliver services with reasonable care and skill When acting for another, act in the best interests of that other
How much can an investor regarding crowd source funding invest each year?
10,000
How many days prior to the policy renewal date must an insurer tell the policy holder whether it is prepared to renew the contract?
14
What year did the speculative boom happen?
1800s
What year was the Reserve Bank of Australia created?
1960
year the RBA was created
1960
The rollout of ATM commenced what year?
1969
What year was the National Consumer Credit Protection Act (NCCP) formed?
2009
Which year did the Banking and Finance Oath launch?
2013
The Hayne Royal Commission into Misconduct into the Banking, Super. & Financial Services industry was established in what year?
2017
year of better banking program
2017
year of royal commission
2017
Which year did the BEAR regime become effective?
2018
Under RG271, what is the maximum timeframe for firms to provide an Internal Dispute Response (IDR) for a credit-related complaint involving default notices no later than how many days:
21 days
What is the maximum timeframe to respond to credit-related complaints involving default notices?
21 days
To assist in achieving risk management objectives, many banks & financial institutions in Australia have adopted ____ lines of defence:
3
What are the three parts of the money laundering cycle?
3. Integration, 1, Placement, 2. Layering
The liquidity coverage ratio (LCR) requires Australian ADIs to hold sufficient liquid assts to meet how many days?
30
Liquidity Coverage Ratio (LCR) requires Australian ADIs to hold sufficient liquid assets to meet what period of net cash outflows, as projected under an APRA-prescribed stress scenario:
30 days
Under RG271, the maximum timeframe for an IDR response to a standard complaint is:
30 days
What is the standard timeframe you are required to respond to regarding a standard complaint?
30 days
Under the RG271 what is the maximum timeframes for IDR response for a Superannuation trustee complaints?
45 days after receiving the complaint
Crowd funding is an alternative way for start-ups and small/medium companies to raise money. Eligible companies can raise up to how much a year using crowd-sourced funding (so long as they have less than $25 million in assets and annual revenue)
5 million
Where do banks achieve the majority of their funding?
62% of banks receive funding from retail deposits (households and businesses) vs wholesale funding (short to long term debt insurance, 38%)
What is the typically maximum benefit payable on an Income Protection Insurance Policy, what %?
75% of the insured's gross employment earnings
What is a credit guide?
A Credit Guide provides important information about the credit products provided by lenders which are regulated by the National Credit Code.
What are Key Risk Indicators?
A Key Risk Indicator (KRI), is a measure used in management to indicate how risky an activity is. Key risk indicators are metrics used by organisations to provide an early signal of increasing risk exposures in various areas of the business.
What is liquidity?
A bank's ability to meet its anticipated expenses such as funding loans or making payments
What is virtual ethics?
A branch of ethics that considers the characteristics that individuals should possess if their behaviour and acts are to comply with ethical norms.
what is Derivatives market?
A contract whose value is derived from one or more underlying assets or instruments; for example, forward rate agreements or underlying exchange rates
What is advocacy threat?
A threat to independence that arises when an individual is asked to consider an action or take a decision in relation to a person or entity they have previously supported.
Which Australian regulator would prohibit any mergers or acquisitions between two large banks?
ACCC
What's the main difference between ADIs and non ADIs?
ADIs can take deposits from the public and non ADIs can not. Banks don't have members they have stakeholders.
What is AFCA (Australian Financial Complaints Authority)? And how is AFCA funded?
AFCA membership is paid for by financial firms that provide financial products and services AFCA is free for customers and small business
Which regulator has powers over the renumeration policy?
APRA
Who is part of the Council of Financial Regulators?
APRA, Treasury, RBA, ASIC (TARA)
Which regulator provides guidance on identifying and providing services to vulnerable customers?
ASIC
Describe the Corporations Act 2001
An act of the Commonwealth of Australia that sets out the laws dealing with business entities in Australia at federal and interstate level. It focuses primarily on companies, although it also covers some laws relating to other entities such as partnerships and managed investment schemes.
What does ABA stand for and what is it used for?
Australian Bankers' Association provides analysis, advice and advocacy for the banking industry and contributes to the development of public policy on banking and other financial services.
What does AFCA stand for?
Australian Financial Complaints Authority
Health, political opinions, religious beliefs/affiliations, and criminal records are all considered "Sensitive Information" under what?
Australian Privacy Principles
What does APRA stand and responsible for?
Australian Prudential Regulatory Authority responsibility for prudential supervision.
What does ASIC stand for and what does it protect?
Australian Securities and Investments Commission having responsibility for market integrity and consumer protection across the financial system.
What is ADI? Examples?
Authorised deposit-taking institution comprising banks, credit unions and building societies.
Which of the regulatory sought to improve executive accountability in ADI's?
BEAR
In 2017, the Government bought forward a comprehensive package of reforms to strengthen accountability and competition in the banking system. This is referred to:
BEAR, Banking Executive Accountability Regime
what is Emergence of Fintech?
Blockchain - a distributed ledger using peer to peer technology, providing real time records that are replicated amongst participants Bitcoin - a decentralised digital currency that enables instant payments using peer to peer technology
What type of loan is suited a customer who has purchased a new property and sold their old property?
Bridging loan
What is the first line of defence for Risk Management Frameworks?
Business Operations
What is the first line of defence in the risk management framework?
Business Operations
Stacey owns a hairdressing salon. Over the weekend, the store next door had a chemical leak and Stacey and her team had to vacate the premises for a week and couldn't work. Luckily, Stacey had insurance to cover her. What type of policy did she rely on in this scenario?
Business interruption
Which of the following describes the risk associated with the vulnerability of a line of business to changes in the business environment?
Business risk
What are the four C's of Credit?
Character, Capacity, Collateral, Capital
What are the main differences between commercial banking and investment banking?
Commercial banks service retail, business and corporate customers, taking deposits and granting loans, whereas investment banks service large corporate, institutional and government customers and act as an intermediary in large capital raising transactions.
Which market trades cattle and wheat?
Commodities Market
what is indemnity policies?
Compensating an individual for a financial loss. Indemnity clauses are included in most insurance contracts to ensure that the policy owner is compensated only for their loss and does not profit and receive an amount in excess of the amount of the loss suffered.
An employee of a company colluding with a friend to enter fraudulent orders for personal gain is an example of...what type of risk?
Conduct Risk
What were three amendments made to the Corporations Act in 2012.
Conflict remuneration, Scaled Advice, Fees Disclosures
A family is deciding if they should purchase a new tablet. There is a lot of debate ranging around various topics such as cost, model and concerns about the content and excessive usage. Peter has got right into to the detail! He understands the numbers inside out and has weighed up the pros and cons coming to a decision that he feels would give the best benefit with the least amount of cost. He knows his decision will have consequences, but is happy to accept them. what ethical approach did he take?
Consequentialism
The risk that problems arise in other internal business channels which could compromise the financial and operational position of the ADI is referred to as what type of Risk?
Contagion Risk
what is framing?
Correctly focus on the problem we are trying to solve. It helps to remove 'the noise' from an issue to allow us to see the problem for what it is
What does the Council of Financial Regulators do?
Council has no additional legislative or legal responsibilities separate to those of its members, it performs an important advisory role, contributing to the efficiency and effectiveness of financial regulation and promoting stability of the Australian financial system. CFR aims to: •Facilitate sharing of information amongst members •Discuss regulatory issues •Coordinate responses to potential threats to financial stability if the need arises •Advise governments on the adequacy of Australia's financial regulatory arrangements
What were the risks addressed by Basel II?
Credit Risk, Operational Risk, Market Risk
What does a Risk Appetite Statement provide?
Direction to senior management on the type of activity the board wishes to engage in
Talking to others and seeking their opinions. What step would that fall under in the 5-step process for Ethical Dilemmas?
Discuss
Sandy and John make an appointment with their banker to apply for a home loan at XYZ bank. Daniel goes to the same bank to organize a term deposit. Ruth is planning to set up a savings account with the same bank. Who are XYZ bank's creditors?
Daniel and Ruth
A family is deciding if they should purchase a new tablet. There is a lot of debate ranging around various topics such as cost, model and concerns about the content and excessive usage. Mary is taking the approach that she needs to provide a tablet for her family. We live in the digital age and the family will fall behind otherwise. By purchasing the tablet she feels that she's doing her duty by providing for her family. She believes that every child should have the right education and that this will improve this opportunity. what ethical approach did she take?
Deontology
In some cultures, children are taught to always respect and obey their elders because this is the right thing to do. Children must obey their elders regardless of the reason or consequences. This is an example of:
Deontology
The team has been presented with a customer complaint whereby the customer would like to receive $10,000 in compensation. The customer had their power of attorney revoked as they were suspected of financial abuse towards a family member. This means the customer couldn't pay bills for their family member and the experience caused distress and financial loss. The at conclusion of the investigation, it wasn't proven that the customer had financially abused their family member, but the bank was in their rights to protect the family member while the investigation was taking place. Sam hasn't paid much attention to it and when asked, suggest that we can wait until a more formal complaint is lodged with an external body. He says it may not even get that far, so let's wait until it does. what decision making technic did he use?
Do nothing
What type of corporate social responsibility is the foundation on which all other types of responsibilities rest upon?
Economic
___________________ are the foundation of the Carroll's Social Responsibility Pyramid
Economic Responsibilities
What is the four-step process to follow when handing customer complaints?
Empathise, gather facts, solution, verify
What are the key indicators to assess the performance of the economy?
Employment rate, CPI (Consumer Price Index), GDP, retail sales, building approvals, balance of payments, average weekly earnings, wage inflation
Customer analytics and big data
Enabling a more personalised approach to targeting and engaging consumers
__________________ policies combine a pure term insurance component with a savings element.
Endowment Insurance
A Cricket Club is organising their end of season presentation night. There are a range of dates available including easter Saturday which would involve having it at the clubrooms, whereby they can make money behind the bar, however this may not be the best date for all and the clubrooms are unavailable at other times. Susan would love it to be on Easter Saturday, but is aware that a lot of club members have holidays planned for easter which will mean they can't attend. She suggests it is moved to a different date. what consequential ethical approach did she take?
Ethical Alturism
what is the FIRB Financial system regulation responsibilities?
Examines proposals from foreign interests to undertake direct investment in Australia
The team has been presented with a customer complaint whereby the customer would like to receive $10,000 in compensation. The customer had their power of attorney revoked as they were suspected of financial abuse towards a family member. This means the customer couldn't pay bills for their family member and the experience caused distress and financial loss. The at conclusion of the investigation, it wasn't proven that the customer had financially abused their family member, but the bank was in their rights to protect the family member while the investigation was taking place. Bharath is not sure what all the fuss is about. His role is to conduct further investigations, but he has seen this many times before and just wants to pay the compensation as he knows it is what will happen anyway regardless of how much work he puts in. He's happy to move onto other activities and feels this an easy way to approach the situation. what decision making technic did he use?
Expediency
what is big data?
Extremely large sets of data that can be analysed by computers to reveal patterns and trends, especially in relation to human behaviours, decisions and interactions. When dealing with personal data, organisations must pay due regard to the provisions of the APPs.
Step 2 of the 5-step process for ethical dilemmas is:
Facts
What type of information can you provide to a customer without having to be licenced by an AFSL?
Factual
Luke works at the ABC Bank Call Centre. A customer asks about a new credit card, and Luke informs a customer about the interest rate charged, the annual fee and the rewards program. Luke is providing which of the following?
Factual information
Which type of account is a tax-effective account that allows primary producers to set aside pre-tax income as a cash reserve?
Farm management deposit account
The team has been presented with a customer complaint whereby the customer would like to receive $10,000 in compensation. The customer had their power of attorney revoked as they were suspected of financial abuse towards a family member. This means the customer couldn't pay bills for their family member and the experience caused distress and financial loss. The at conclusion of the investigation, it wasn't proven that the customer had financially abused their family member, but the bank was in their rights to protect the family member while the investigation was taking place. Natasha had a quick look at the case notes and made her decision. She didn't worry about finding out further details or asking questions what decision making technic did she use?
Fast and slow thinking
The Corporation Act 201 outlines the range of disclosure documents, that must be provided to retail customers, which 2 documents?
Financial Services Guide & Product Disclosure Statement
What are the three lines of risk defence?
Framework used within the Banking Industry to manage risk. 1st line of defence - Risk management by business operations, individual business units and operation teams. 2nd line of defence - Risk management by risk and control functions having independent risk control and compliance oversight, reviewing, guiding and developing risk frameworks to support level 1. 3rd line of defence - Internal audit reviewing both line 1 and 2 providing an independent perspective and assurance.
The team has been presented with a customer complaint whereby the customer would like to receive $10,000 in compensation. The customer had their power of attorney revoked as they were suspected of financial abuse towards a family member. This means the customer couldn't pay bills for their family member and the experience caused distress and financial loss. The at conclusion of the investigation, it wasn't proven that the customer had financially abused their family member, but the bank was in their rights to protect the family member while the investigation was taking place. Kenton is getting frustrated at what's going on, so he decides to hold a meeting and present all the facts to everyone, so that they can agree the problem they're trying to solve and make sure its framed correctly. what decision making technic did he use?
Framing
Mutually owned co-operative financial institutions offering benefits to members through a trust-like structure" describes which type of Insurer/Fund Manager?
Friendly Society
Samuel explains that the XYZ savings booster account has a bonus interest rate and is a good choice for customers who want a higher return on their account and do not need to access their funds. What type of advice is Samuel providing?
General advice
What is fiscal policy?
Government spending and taxation that influences the economy The annual budget includes revenue sources and spending activities. eg. make money - GST, collecting taxes, borrowing funds. Spending - welfare payments, defence, capital projects
What is GDP?
Gross domestic product (GDP) is the total monetary or market value of all the finished goods and services produced
The team has been presented with a customer complaint whereby the customer would like to receive $10,000 in compensation. The customer had their power of attorney revoked as they were suspected of financial abuse towards a family member. This means the customer couldn't pay bills for their family member and the experience caused distress and financial loss. The at conclusion of the investigation, it wasn't proven that the customer had financially abused their family member, but the bank was in their rights to protect the family member while the investigation was taking place. The group....In Kenton's meeting John is very adamant that the customer is in the wrong and has a very strong personality. Sam says that as the case is very grey, they should wait until the customer contacts them again. The rest of the "group agree", despite having differing opinions. what decision making technic did he use?
Group Conformity
What is the process of risk assessment?
Identification, analysis, and evaluation
Basel II 2007 included:
Improvements to market discipline by requiring firms to publish certain details of risks, capital and risk management
When was the four pillars policy introduced and what is it?
In 1990 the government adopted a 'four pillars policy' in relation to banking in Australia and announced that it would reject any mergers between the four big banks (CBA, NAB, Westpac and ANZ)
What is "Chinese walls" ?
Information barriers within the organisation to prevent exchanges or communication lead to conflicts of interest
Investing distanced funds or assets in further criminal activity, is known as which stage of the money laundering cycle:
Integration
What are the values of the FINSIA code of conduct?
Integrity, Professionalism, Objectivity and Respect
What is Financial intermediation
In simple terms, is the process of pooling funds from savers and using these to provide loans to borrowers.
What is indemnity insurance?
Indemnity insurance is a contractual agreement in which one party guarantees compensation for actual or potential losses or damages sustained by another. Most commonly, it is an insurance policy designed to protect professionals and business owners when found to be at fault for a specific event such as misjudgment.
What sits under Macroeconomics?
Inflation Exports and imports Unemployment rates GDP
What is the considered to be the third line of defence
Internal Audit
Elliot works in the lending team at NAB. A client has come into the bank and is threatening to take Elliot to court if he doesn't approve his home loan before the end of the client's settlement period. What is the chief threat to Elliot acting professionally in this matter?
Intimidation
The team has been presented with a customer complaint whereby the customer would like to receive $10,000 in compensation. The customer had their power of attorney revoked as they were suspected of financial abuse towards a family member. This means the customer couldn't pay bills for their family member and the experience caused distress and financial loss. The at conclusion of the investigation, it wasn't proven that the customer had financially abused their family member, but the bank was in their rights to protect the family member while the investigation was taking place. John is sure that the customer was up to no good. He just didn't like the way she spoke and avoided eye contact. He checked and re-checked all of the statements to try and find evidence to prove this. what decision making technic did he use?
Intuition
Describe the privacy act 1988
Is an Australian law which regulates the handling of personal information about individuals. Personal information is information or an opinion about an identified individual, or an individual who is reasonably identifiable.
What is solvency?
Is the ability of a bank to meet its long-term financial obligations. Solvency is essential to staying in business as it indicates a company's ability to continue operations into the foreseeable future.
What is fiscal policy?
Is the government spending and taxation that influences the economy.
What is conduct risk?
Is the risk of inappropriate, unethical or unlawful behaviour on the part of a bank's management or employees.
what is the formula for Loan to Value Ratio (LVR)
LVR = Loan amount/asset value * 100
How do we decide on what level of interest to apply?
LVR; Risk Profile; Loan amount; Based on risk appetite; Based on competition; History; RBA rates; Product type (e.g. fixed or variable rate)
"This policy says the policy owner in the event of life insured dying within the term of the contract" This statement defines which type of insurance?
Life insurance
What is LCR?
Liquidity Coverage Ratio. The banks ability to meet its 30 day commitments. Hold sufficient liquid assets
Basel III requirements addressed which additional risk:
Liquidity Risk
Downtown bank collapses and files for bankruptcy. It is one of the major banks in its country, and its collapse has serious negative impacts on the overall economy. This is an example of which type of risk?
Macro-prudential risk
what is conduct risk?
May arise because of inappropriate, unethical or unlawful behaviour on the part of bank employees. APRA and ASIC have an interest in conduct risk.
What makes an effective Key Risk Indicator, select the correct response:
Measurable, Predictable, Informational
The RBA uses which policy to influence the economic environment?
Monetary Policy
Non ADIs, which institutions is part of non ADI
Money market corporates, finance companies, securitisation vehicles
Is the bank the Mortgagee or Mortgagor
Mortgagee
What is NCCP Act 2009
National Consumer Credit Protection Act 2009 Legislation that's designed to protect consumers and ensure ethical and professional standards in the finance industry.
What is NSFR?
Net Stable Funding Ratio. Holding enough assets to reduce funding risk over a one year horizon as prescribed by APRA
What is the Net Worth equation?
Net Worth = Assets - Liabilities
Under RG271 the maximum timeframe for Standard Complaint must be:
No later than 30 calendar days after receiving the complaint
When must a standard complaint be responded to?
No later than 30 calendar days after receiving the complaint
what is over the counter markets?
Non - standardised negotiation between the parties involved in the transaction Over the branch counter
The team has been presented with a customer complaint whereby the customer would like to receive $10,000 in compensation. The customer had their power of attorney revoked as they were suspected of financial abuse towards a family member. This means the customer couldn't pay bills for their family member and the experience caused distress and financial loss. The at conclusion of the investigation, it wasn't proven that the customer had financially abused their family member, but the bank was in their rights to protect the family member while the investigation was taking place. David recently read a similar story from another bank whereby they had to pay out $20,000. He suggests that $10,000 is a bargain so we should do the same as the other bank. what decision making technic did he use?
Not thinking
Describe the layering stage
One of the stages in the money laundering process, when there is a series of multiple transactions, designed to hide the original source of the 'dirty' money.
Describe the process of placement
One of the stages in the money laundering process, where the proceeds from criminal activity first enter the financial system.
Risk loss that includes a broad range of factors including human error, fraud, failure of information systems, problems related to personnel management, commercial disputes, accidents, fire and flood is what type of Risk?
Operational Risk
_________________ is the risk of loss resulting form inadequate or failed internal processes, people and systems, or from external events.
Operational Risk
What is the main purpose of financial intermediation?
Pass on funds from savers to borrowers in an efficient manner
Banks & other NBFI's participate in the Financial markets as ______________
Price Makers
The World Water Corporation issues new shares direct to the public to fund capital works. This is an example of what type of market?
Primary Market
What are the 4 types of Financial Markets?
Primary market, secondary markets, exchange traded markets and over the counter markets
The four pillars of fiduciary duty are:
Principles, process, prudence, consistency
What act legislates PROVIDING PRIVACY AND CONFIDENTIALITY to our customers?
Privacy Act 1998
Which of the document is not a Responsible Lending Disclosure Document?
Product Disclosure Document
Why is a 3rd party guarantee considered an asset?
Promise to pay.
Monetary policy is overseen by:
RBA
What step in the 5 Step Process for Resolving Ethical Decisions is where you think about the issue and write everything down?
Recognise
The Five Step process for Ethical Dilemmas is:
Recognise, Facts, Discuss, Act, Review
What is the 5-step process for Ethical Dilemmas?
Recognise, facts, Discuss, act, review
What is market risk?
Refers to the risk of an adverse impact on a Bank's valuations and profits resulting from changes in market factors, such as foreign exchange rates, interest rates and commodity or equity process.
What is compliance risk?
Refers to the risk of legal or regulatory sanction, financial or reputation loss arising from a bank's failure to abide by the compliance obligations required by law, rules, standards or codes of conduct.
What is utilitarianism?
Relevant to ethics. Utilitarian's pursue decisions and actions that will bring the greatest benefit to the maximum number of people.
Which of the regulatory bodies is the "lender of last resort"?
Reserve Bank of Australia
What Economic Key Indicator is an indicator of Consumption?
Retail sales
In regard to the Three Lines of Defence model, which is considered the second line of defence?
Risk & Control functions
What are the main steps of the Risk Management Process:
Risk Assessment, Risk Identification, Risk Analysis, Risk Evaluation, Risk Treatment
What are the three steps of Risk Assessment?
Risk Identification, Risk Analysis, Risk Evaluation
What the second line of defences in RISK
Risk and Control
what is Artificial intelligence
Robotics - 'Trading without a trader' and is already being used for back office tasks and to identify fraudulent activities
"Typically operated with a plastic card, mobile app or in a few cases by passbook" and "level of interest rate varies depending on both the balance of the account and the terms of the account" best describe which account type?
Savings
a. Where these securities are traded after their initial issue, like a "second hand" market, where securities that have already been issued through the primary market are traded again, this is known as what market?
Secondary
After an IPO, where can shares be traded on?
Secondary Markets
Sally has an ongoing business banking relationship with AAA Developments, who is applying for large commercial lending for a large shopping centre close to where Sally owns some investment properties. She really wants her credit manager to approve the lending for AAA Developments as it will mean capital growth in her suburb, and she can expect values of her own properties to increase dramatically. What is the main threat to Sally acting professionally?
Self-interest
When recording all information about a particular ethical dilemma, it's essential to critically analyse the value judgements being made by each person involved as they record their version of events" What step of the five-step ethical decision model is this statement referring to
Step One - Recognise
Which key indicator is used for fiscal policy?
Taxation
What is banking & finance oath?
The Banking and Finance Oath is founded on a shared belief in the inherent 'good' of the banking and finance industry. The Oath is an effort to improve the society by building trust and confidence in the industry.
What is liquidity?
The Banks' ability to meet all expenses using only liquid assets
what is monetary policy
The RBA is responsible for Australia's monetary which aims to maintain price stability, full employment and economic prosperity by managing inflation . Monetary policy involves - setting interest rates on overnight loans in the money market 'cash rate' which influences other interest rates and affects borrows and lenders, economic activity and inflation.
What is equity risk?
The potential for financial loss arising from movements in equity/ asset values.
what is market risk?
The risk of an adverse impact on a bank's valuations and profits resulting from changes in market factors (E.g. foreign exchange rates, commodity prices).
What is consequentialism?
The right decision is the one that achieves the best outcome (or benefit) with the least amount of harm (or cost).
What is deontology? AKA KANT
The right thing to do is your duty, regardless of whether you want to. There is a set of rules you follow, and you would expect everybody else to follow.
what is virtue?
The right thing to do moves us toward being the best version of ourselves, if we live up to our own standards. it is flexible, be true to ourself, fulfilling life, is that the best version of me? aka Aristotle the golden mean
what is liquidity risk?
The risk a bank or financial institution does not have sufficient level of liquid asset (assets that are easily converted to cash) to meet current and future obligations.
What is business risk?
The risk associated with the vulnerability of a line of business to changes in the business environment.
What is self-interest threat?
The threat that a financial or other interest will inappropriately influence the professional's judgement or behaviour.
What is intimidation threat?
The threat that a professional will be deterred from acting objectively because of actual or perceived pressures, including attempts by another to exercise undue influence over them.
Describe corporate social responsibility
The ways in which a company manages its business in order to have an overall positive impact on society. It can be described as an obligation, beyond that required by the law, for a business to pursue long term goals that are good for society.
What are some of the obligations of AFSL licensees?
There are key AFSL Licensee obligations contained in the Corporations Act 2001 and accompanying ASIC regulatory guides. Licensing Obligations - sets out general obligations of AFSL licensees with respect to: •Conduct and disclosure and the provision of financial services to retail clients. •Competence, knowledge and skills of responsible managers, and authorised representatives. •Authorised representative's compliance with the financial services laws. •Compliance, managing conflicts of interest and risk management processes. •Adequacy of financial, technological and human resources. •Provision of dispute resolution and compensation arrangements.
When looking at the 'Customer Lifecycle' what is true when it comes to 'Independents'
These are younger people who are likely to be earning an income but have no dependants
What is the main threat posed to a bank's profitability arising from new technologies of bitcoin and blockchain?
They both use peer to peer technology meaning no third party central authority is required to process payments or reconciliations
what is replacement value policy
Under this arrangement the sum insured, and premium are increased annually. The sum insured, must appropriately reflect the replacement value of the asset. This entitles the insured to have the damaged or lost property replaced with new property that is equal in value to the previous existing property.
A Cricket Club is organising their end of season presentation night. There are a range of dates available including easter Saturday which would involve having it at the clubrooms, whereby they can make money behind the bar, however this may not be the best date for all and the clubrooms are unavailable at other times. Anu believes that making the money is good, but so is having a lot of people attend. He eventually decides that its best for the club to have as many people come as possible so that they can build a stronger culture. He decides to support it being on an alternative date to Easter Saturday. what consequential ethical approach did she take?
Utilitarianism
Sarah has a $100,000 loan and chooses a fluctuating interest rate and the capacity to make additional repayments over the life of the loan. What type of interest rate is Sara applying to the loan?
Variable
A family is deciding if they should purchase a new tablet. There is a lot of debate ranging around various topics such as cost, model and concerns about the content and excessive usage. Sonal is okay to support the idea of a tablet, but is concerned about inappropriate content being available as well as it being used for too long. She said she'll only agree if suitable content protection software is downloaded and that there is a limit as to how much each person uses. This makes her feel comfortable that she has done everything in her power to make this a good decision. She knows she can sleep well at night as a result of making this decision. what ethical approach did she take?
Virtue
How would you classify the following customers according to the 'retail' or 'wholesale' definition? Sally, the CEO of a large organisation looking to invest $600,000 worth of bonds into her SMSF which has $5 million in gross assets
WHOLESALE EG $2.5M
Can algorithms display bias?
Yes it can be, the person who designs it thinks and puts the bias in. The machine can't have moral agency because it doesn't think - it just does.
what is Equity Capital markets
When a company needs money to grow and chooses to raise the funds by undertaking an Initial Public Offering (IPO)
what is Private Mergers & Acquisitions
Where a company is looking to buy another company, and an investment bank acts in an advisory role, including pricing the offer
what is Debt capital markets
Where a large company is looking to issue bond financing to finance an expansion or raise capital. An investment bank would help issue and sell the bonds
What are private placements?
Where customers place an offering of bonds with an institutional investor such as an insurance company or a retirement fund.
when is Private placements
Where customers place an offering of bonds with an institutional investor such as insurance company or a retirement fund.
what is primary market?
Where new issues of shares of other forms of security are offered to the market for the first time e.g. if a gov wants to fund a road building project, it may choose to fund this by borrowing funds on the market and issuing government securities
What is moral absolutism?
Where there is a universal moral principle where everyone's actions are judged - absolutely right or wrong
what is secondary market?
Where these securities are traded after their initial issue, like a "second hand" market
A person who reports information, usually gained from their employment, concerning illegal or unethical activities or misconduct within an organisation is called a:
Whistleblower
Self Review can be a threat to professionalism when:
You are involved in auditing or evaluating the work of others
who is the national regulator for consumer credit and consumer leases?
asic
What are the three regulatory agencies that work alongside the Treasury to make up the Council of Financial Regulators?
asic, rba, apra
what is adi
authorised deposit taking institutions
A reverse mortgage is which type of consumer lending product?
b) Home Loan
What are examples of bearer negotiable instruments?
bank drafts, promissory notes, traveller's cheques, etc. Portable ways to smuggle high-value assets across international borders. Criminals may attempt to purchase BNI's with co-mingled funds (consisting of legitimate business earnings and the proceeds of crime) to camouflage the connection to underlying crimes.
A Cricket Club is organising their end of season presentation night. There are a range of dates available including easter Saturday which would involve having it at the clubrooms, whereby they can make money behind the bar, however this may not be the best date for all and the clubrooms are unavailable at other times. Vinod lives close to the clubrooms. He thinks about it and realises that by having the event on easter Saturday, it will save him having to travel to a venue which could be quite far away. He supports the idea of the presentation night on Easter Saturday. what consequential ethical approach did he take?
ethical egoism
what is foreign exchange market?
exchanging one currency for another
What is a commodity market?
exchanging primary products - wheat or grmoneain
Which stage of the customer life cycle would have the most debt?
family
What are the 8 types of sensitive information according to the Australian Privacy Prinples? (privacy act 1988)
health, religious beliefs, sexual orientation, racial or ethnic origin, philosophical beliefs, criminal records, political opinions, members of political association
what is ethical foundations?
often outline in code of ethics or conduct - sets out what an employee can or can't do?
How would you classify the following customers according to the 'retail' or 'wholesale' definition? Jake's rollerblades, a small business with 11 employees who wishes to establish on-line international payment facilities to support their business growth
retail - less than 20 staff
what is the ato Financial system regulation responsibilities?
revenue collection
What type of mortgage is this? Allowing a home owner to borrow money using the equity in their home as security. The loan can be taken as a lump sum, a regular income stream, a line of credit or a combination of these options. These mortgages are designed for peopled aged 55 years and over and are most taken out by those who have no current outstanding mortgage commitments.
reverse mortgage
Is a rules-based approach leaning on the deontology, consequentialist and/or virtue approach to ethics?
rules based - more consequentialism/deontology
what is the difference between rules based vs principle based approach
rules based - sets out clearly what a memeber can or can't do Principles - sets out the broad "high-level" principles for members to comply with. How members go about complying with these is up to them. this is more of a guidance that can be applied.
what is equity market?
shares in listed companies
What is moral relativism?
the opposite of moral absolutism. There is not always a right answer.
What is the purpose of BEAR?
to improve executive accountability in ADIs, recognising leadership is key to driving cultural change
what is interest rate or debt market?
trading bonds - short term and long term securities
what are the types of different types of insurance?
travel insurance, car insurance, health insurance, business insurance, consumer credit insurance
What does a budget surplus or deficit mean?
when government Collect more than they spend. Deficit - spend more than they collect
what is the banking and finance oath?
•An individual's commitment to do the right thing and be ethical •Building trust within the community after the Royal Commission. How can we as bankers demonstrate we are trustworthy and have integrity. We own this individually. •Founded on a shared belief in the inherent 'good' of the banking and finance industry •An industry-led initiative launched in 2013 •Contains a set of commitments that individuals working in Financial Services can choose to adopt and apply as personal principles in their work. •Re-asserts the ethical foundation of the industry beyond regulation and compliance •Provides individuals and teams with a common ground for ethical discussions
What are whistleblowers principles?
•Bank executives need to demonstrate strong and visible leadership. •Bank whistleblower policies must allow for disclosures on a range of issues from a range of people who have a connection with the bank. •Banks are to provide clear guidelines on the reporting and investigation process. •Banks will provide support and protections for whistleblowers. •The whistleblowing program is known, accessible and effective training is provided. •On an ongoing basis, banks will monitor the awareness and effectiveness of a whistleblower program.
Why was legislation imposed to mandate reserve requirements for banks? And what does this mean?
•Cash reserves requirements are intended to ensure that every bank can meet any large and unexpected demand for withdrawals •Following the 1929 stock market crash that led to the Great Depression, Governments responded with legislation imposing reserve requirements on banks, mandating that they hold above a certain percentage of liabilities as cash reserves. •Bank regulators also introduced additional capital and liquidity requirements in response to the Global Financial Crisis (GFC) in the late 2000s.
What do applicants need to demonstrate to obtain an Australian Financial Services License (AFSL)?
•Competence, skills and experience •Financial resources necessary to perform the proposed activities
2.Payment System Board ensures the payments system contributes to:
•Controlling risk in the financial system •Promoting the efficiency of the payments system •Promoting competition in the market for payment services
In practical terms, what does ASIC do?
•Develop policy and guidance about the laws that it administers •Grant licenses and monitoring compliance by participants in the financial system •Supply information on companies and corporate activity (e.g. company searches)
what is the treasury responsible for?
•Economic policy •Fiscal policy •Market regulation •The Australian Federal Budget
what is the treasury function?
•Participation in regulatory reforms to improve the resilience of the financial system •Innovation and consumer outcomes •Participation in regional and international forums, such as G20 summits
What are the top 3 lending considerations banks need to make?
•Person applying for the loan •Amount, purpose and term of the loan •Persons ability to repay the loan
What are some of the key benefits of lending for a bank?
•Primary source revenue to a bank •Identifies opportunities for banks to generate revenues from additional sources •Allow clients to realise their aspirations
What are APPs?
•Set out the obligations for the organisations that collect the data •Helps define what purpose it should be used for •How we store the data •Set out the rights and data subjects and the obligations of organisations which collect, process, analyse, use and store personal data.
In practical terms, what does the RBA do?
•Setting the cash rate to meet an agreed medium term inflation target •Working to maintain a strong financial system and efficient payments system •Issuing the nation's banknotes •Providing banking services to the Australian Government and its agencies, and to a number of overseas central banks and official institutions •Managing Australia's gold and foreign exchange reserves.
1.Reserve Bank Board ensures monetary and banking policy contributes to: 3 things
•Stability of Australian currency •Maintenance of full employment •Economic prosperity and welfare
Why is the RBA considered a 'lender of last resort'?
•The RBA uses its power and influence to promote stability in the Australian financial system. If a financial institution is facing liquidity issues and was unable to make payments, the RBA could lend directly to that financial institution and provide emergency liquidity support. •The lender of last resort functions to protect individuals who have deposited funds and to prevent customers from withdrawing out of panic from banks with temporary limited liquidity. As banks only keep a percentage of total deposits as cash, a bank's liquidity can be quickly drained by panic withdrawing of funds by its customers and cause the bank to become insolvent.
What is behavioural credit scoring?
•The savings pattern of the customer •The regularity of credit payments made •Any unpaid items
What are the lending obligations under NCCP?
•To act efficiently honestly and fairly •To ensure clients are not disadvantaged by any conflict of interest