Important obligations.

We pride ourselves on our integrity and focus on doing what’s right for our customers. We pledge to operate within the financial services regulatory requirements, responsibilities and obligations. We know you do too.

Summary of important obligations.

Know Your Customer (KYC)

Conduct due diligence ensuring all relevant customer information is collected and verified for AML identification purposes. The same information may also be used to satisfy VOI (Verification of Identity) for Land Titles Office purposes.

Suspicious Matter Reporting

Brokers are required to report any unusual or potentially suspicious matter to Bankwest. Report suspicious matters by emailing BankwestAML@cba.com.au.

Anti-Bribery and Corruption

At Bankwest, we take a zero tolerance approach to bribery, corruption and facilitation payments. We expect that you act honestly and ethically at all times. If something doesn’t look right to you, let us know immediately.

Find out more about the Group's external Anti-Bribery and Corruption Policy.

What is PDDO?

The Product Design and Distribution Obligations (DDO) are legal obligations that apply to Bankwest under the Corporations Act. The DDO require issuers and distributors to develop and maintain effective product governance arrangements across the life cycle of financial products, which includes the creation and maintenance of Target Market Determinations (TMDs) for in scope products.

What is a TMD?

A Target Market Determination, or TMD, is a mandatory document that is required for all in scope products. The document, created by the product issuer, describes:

  • the class of customers who comprise the product’s target market;
  • any conditions and restrictions on how the product can be distributed to customers;
  • events or circumstances that will require Bankwest to review the Target Market Determination for a financial product; and
  • (for some products) the information that third party distributors must provide Bankwest.
  • TMDs for Bankwest products can be found at bankwest.com.au/tmd.

Sell in line with the TMD

You should be aware of the TMD, including the relevant target market and the distribution conditions for the products that you are distributing.         

NCCP Act

The National Consumer Credit Protection Act 2009, or the NCCP Act, is legislation that's designed to protect consumers and ensure ethical and professional standards in the finance industry.

Privacy Act

Australian legislation about protecting and handling of personal information about individuals. This includes the collection, use, storage and disclosure of personal information.

Banking Code of Practice

The Banking Code of Practice (the Code) sets out the standards of practice and service in the Australian banking industry for individual and small business customers, and their guarantors.

Responsible Lending is a provision of the National Consumer Credit Protection Act 2009. NCCP and Responsible Lending requires that all Lenders and Credit assistance providers ensure that customers do not enter into credit contracts that are considered “unsuitable”. These obligations can be found in ASIC Regulatory Guide RG209.

As a Broker, a significant component of the service and advice you provide is ensuring that the loan product that you recommend is suitable for the customer’s requirements and objectives.

What are your Responsible Lending obligations as a Broker?

  1. Ensure you’re making reasonable enquiries regarding your customer’s financial situation, requirements and objectives.
  2. Take reasonable steps to verify the customer’s financial situation. These can include:
    • Running through the customer’s monthly living expenses and what they believe they spend monthly
    • Ensuring that the quoted number of dependents matches records (e.g. Medicare Card, Centrelink statements)
    • Verifying all OFI debts which are not being refinanced as part of the home loan application - These requirements must be evidenced by providing one month’s statements for each debt not being refinanced AND one month’s statements for the borrower’s everyday transaction account (most recent transaction must be within 45 days of application submission).
    • Completing a review on each borrower’s everyday transaction account (where not held with Bankwest) for undisclosed debts.
  3. Make a preliminary assessment to determine the proposed credit contract is not considered “not unsuitable”.


What this means at Bankwest

As part of the application submission process, you'll be required to ensure you're making reasonable enquiries regarding your customer’s financial situation, requirements and objectives. These will be captured and shared with the customer in their loan mail pack, so we can make our final assessment considering their full statement of position and requirements and objectives.

If there’s a material change to a submitted loan application, this may have resulted due to a change in the customer’s original requirements and objectives, or financial position. If this happens, we’ll need a Responsible Lending Rework Form to be submitted so we have a record of their revised requirements and objectives. To access this form, visit our Forms page.

SpeakUp.

Our SpeakUp program is a safe platform for you to report concerns about unethical behaviour and corruption.

We encourage all Brokers to speak up about conduct or issues that concern them.

You can report concerns by speaking to your BDM or contact SpeakUp.

Responsible Lending.

Responsible Lending is a provision of the National Consumer Credit Protection Act 2009. NCCP and Responsible Lending requires that all Lenders and Credit assistance providers ensure that customers do not enter into credit contracts that are considered “unsuitable”. These obligations can be found in ASIC Regulatory Guide RG209.

As a Broker, a significant component of the service and advice you provide is ensuring that the loan product that you recommend is suitable for the customer’s requirements and objectives.

What are your Responsible Lending obligations as a Broker?

  1. Ensure you’re making reasonable enquiries regarding your customer’s financial situation, requirements and objectives.
  2. Take reasonable steps to verify the customer’s financial situation. These can include:
    1. Running through the customer’s monthly living expenses and what they believe they spend monthly
    2. Ensuring that the quoted number of dependents matches records (e.g. Medicare Card, Centrelink statements)
    3. Verifying all OFI debts which are not being refinanced as part of the home loan application. These requirements must be evidenced by providing:
      1. one month’s statements for each debt not being refinanced AND
      2.  one month’s statements for the borrower’s everyday transaction account (most recent transaction must be within 45 days of application submission).
    4. Completing a review on each borrower’s everyday transaction account (where not held with Bankwest) for undisclosed debts.
  3. Make a preliminary assessment to determine the proposed credit contract is not considered “not unsuitable”.


What this means at Bankwest

As part of the application submission process, you'll be required to ensure you're making reasonable enquiries regarding your customer’s financial situation, requirements and objectives. These will be captured and shared with the customer in their loan mail pack, so we can make our final assessment considering their full statement of position and requirements and objectives.

If there’s a material change to a submitted loan application, this may have resulted due to a change in the customer’s original requirements and objectives, or financial position. If this happens, we’ll need a Responsible Lending Rework Form to be submitted so we have a record of their revised requirements and objectives. To access this form, visit our Forms page.