Regulatory breach brief
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Project Budget$30 - $250 USD
Your job is set out below. must be completed within 12 hours.
You are a Group Regulatory Compliance Officer reviewing loss events, when you note the following loss event:
A customer complaint was received from Mother on behalf of Son by the Canberra Branch on 10 August 2012. The complaint was forwarded on to Customer Help Centre (‘CHC’) on 16 August 2012 and appeared to relate to maladministration (i.e. responsible lending) in lending due to the customer’s 'mental capacity'. The maladministration claim was addressed by CHC; however, upon further investigation, there was also a component of financial hardship which was not addressed.
Unfortunately, the reference to financial hardship was not identified by either the Canberra Branch or CHC as the complaint was investigated from a maladministration perspective only.
The CHC representative that loaded the breach has noted it down as a breach of ASIC Regulatory Guide RG165 and the National Credit Code.
Task: The Risk Business Partner for Retail has asked you for a brief note (no more than a page) explaining the regulatory breaches, as the Risk Business Partner has to back brief the Head of Retail.
Bonus question 1: Using the Regulatory Legal column on the consequence table (on this intranet link http://intranet/procedures/policies/docs/[url removed, login to view]) what level would you rate the event as? Would it make any difference if ASIC had of identified the breach instead of the Bank?
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