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Our team of compliance specialists, industry lawyers and instructional design experts helped Unity Bank and others meet the challenge of getting compliant with the totally re-written industry code in a very short timeframe.
In 2022 the Customer Owned Banking Association (COBA) introduced a new version of the Customer Owned Banking Code of Practice (COBCOP). The new Code represented a significant change from the existing Code and its adoption by subscribers involved a number of challenges. All the subscribers to the Code are clients of GRC Solutions, and many of them have for years relied on our training and support products. Accordingly, we needed to be involved from an early stage in supporting our clients through this change.
Unity Bank, a significant mutual bank based in Sydney, was one of the first businesses to make informal contact with GRC Solutions seeking an understanding of what support we would be able to develop and provide to help them comply with their obligations under the new Code. Discussion with industry participants revealed that the scope of the necessary support was large – our clients needed: support to understand the nature of the changes and to build the knowledge and talent necessary to develop internal processes; check-ins to ensure businesses were on the right track; and training at multiple levels in their business.
It became clear that clients would require a wholistic training project covering multiple aspects of the regime and the differing interests of multiple areas within their businesses.
The particular changes that needed to be addressed were:
The wide-ranging nature of these changes meant that Code subscribers would need to modify their processes and training in a number of other areas of their core business, including:
Two of the most challenging aspects of the project to introduce the new COBCOP to subscriber businesses were
While COBA had published an indicative paper relating to the changes in late 2019, no further clarification was published due to the desire to wait to see whether Treasury would move to make certain Code provisions legally enforceable. In late 2021/early 2022 the project moved ahead, but the new Code then had to be submitted to the ACCC for approval of certain aspects. A start date of 1 October 2022 was announced, but it was noted that the necessary submission to the ACCC had not yet been lodged. It was lodged in April 2022.
Interim authorisation was granted by the ACCC in late May with projected final authorisation – pending public comments – in late July.
Final authorisation was granted in early August.
Given that aspects of the Code remained subject to this regulatory review, GRC Solutions' support for the sector necessarily took a staged, progressive character, flagging significant proposed changes and undertaking awareness and updating activities in advance of rolling out the actual training products once final ACCC authorisation was granted.
The Project Design responded to these challenges as follows
Three micro-learning bulletins were published over the period 2020-2022 comparing the existing Code with the new one, to allow Compliance and L&D staff within subscribing banks to update themselves on the expected changes. The micro-learning highlighted areas where in the opinion of our compliance experts managers needed to retrain themselves and change the focus of units and staff within their businesses.
We also published indicative timelines for the publication of the final training products to allow L&D staff to manage training schedules in advance.
2. Pre-introduction webinars
While COBA was managing the roll-out of the new Code to its members, we advocated for pre-introduction training events for responsible managers, including directors. COBA set up two such webinars in the period between the lodgment of the application for ACCC authorisation and the granting of provisional authorisation.
Two of GRC Solutions’ experts presented. In our view the greatest benefit we could add lay in highlighting the risks, pain points, and areas where most focus and the greatest work would be needed to achieve Code Compliance within that short time frame.
The micro-learning acted as a ‘heads up’ preparing compliance and risk management staff for the changes in store. The keystone piece in the process was the publication of the Customer Owned Banking Code of Conduct Compliance Manual. This is the crucial training product for management, as it allows them to update themselves on processes and to comprehend a standard against which to evaluate their own and their business’ processes and procedures, and to upskill themselves to manage and evaluate those processes and procedures ongoing.
4. Online training products for customer-facing staff
While there are numerous changes in the new Code that require process development, IT updates, and product reviews with subscribing businesses, the most significant requirement involves the upskilling of customer-facing staff to empower them to be code-compliant in their dealing with customers from day one. For the larger businesses, with numerous customer-facing staff across several areas of operation, this is a major challenge.
The majority of Code subscribers already subscribe to GRC Solutions’ Customer Owned Banking Code of Conduct Training and COBCOP Direct Debit Training – eLearning products authored and delivered via our Salt Adaptive® system.
This was an effective training product for the old Code, but the new Code embodied a change of style and emphasis. As a consequence our compliance experts completely re-imagined and rewrote the training, and our eLearning specialists applied completely new designs to better reflect the new style and emphasis.
Despite the fact that research and development of the new products entailed a considerable investment of time and expertise, we were able to roll out the new manuals and training products by the end of August 2022, within three weeks of the Code achieving final authorisation.
Feedback from clients across the industry was very positive, and the new training solution has been taken up by most members of the sector. We have made additional sales of these products to several of the mutual banks that had not previously subscribed.
Veronica Salman, Legal & Compliance Manager at Unity Bank wrote to us to say:
In a rapidly growing industry that is always inundated with new regulatory changes and limited internal resourcing, Unity Bank has always welcomed assistance from groups who understand the importance of collaboratively working together as we reach our common goal of meeting compliance obligations.
GRC has played a significant role in this process as it continuously strives to assist us in imbedding new regulations and developing ongoing guidance materials which we find ourselves using in all processes of our day to day roles. In preparation to implement the updated COBCOP Code, GRC has greatly assisted us in preparing for the new Code requirements. With ongoing updates provided and the release of the new COBCOP manual, the Bank has been able to use this material to develop preliminary guidance for staff to prepare for the implementation of the new Code.
One of the most significant project outcomes is the demonstration once again of GRC Solutions’ capacity to mobilise its resources to create a wholistic response to an industry challenge, and to do so within a constricted timeframe. This represents a considerable step in the understanding of the nature of compliance support in the future. Providers in the compliance space sometimes aspire to being a one-stop shop, but the creation of a multi-part training project takes this further. There can be no doubt that there will continue to be such revolutionary changes imposed on the financial services industry in the short to medium term at least, and similar training product development responses will be needed again and again in the future.
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