The Mortgage & Finance Association of Australia has called for the next iteration of the customer-owned banking code to formally embed mortgage and finance brokers.
The Mortgage & Finance Association of Australia has urged the independent 2025–26 review of the customer-owned banking Code of Practice to lock in stronger recognition of brokers, fairer access to products, and tougher safeguards against scams across the mutual banking sector.
The MFAA began by asking the reviewer to rethink the code’s view of the lending landscape, so it reflected the ecosystem of brokers and digital platforms that now sat between customers and credit.
“We see an opportunity for the Code to adopt a more holistic, ecosystem-based approach that reflects how consumers access and navigate lending today,” the submission read.
The association stressed that brokers were often the first professional contact for borrowers and that they had a “legal obligation to understand a customer’s needs and objectives before making product recommendations”.
On the back of this, the MFAA said it wanted brokers to be explicitly listed in the code’s advice‑referral promise, so that they sat alongside lawyers, accountants, and financial advisers.
The submission put forward a proposed wording for the clause.
“If you ask us for advice about any of our banking services, we will provide advice through staff who are trained to provide that advice, or we will suggest that you obtain advice from a lawyer, accountant, financial adviser, mortgage and finance broker, or financial counsellor,” it read.
Switching, discharge times, and competition
Beyond recognition, the submission called for tighter expectations around refinancing and switching, noting that discharge delays could blunt competition.
The association also said it wanted the code to go further by encouraging lenders to proactively raise alternative options with customers on variable‑rate loans.
It suggested that mutuals be required to prompt customers to actively consider other arrangements.
Discharge processes were another focus, with the MFAA pushing for clearer rights when customers appointed representatives in a refinance.
“More timely and transparent discharge processes where a customer chooses to switch providers, including enabling brokers to act on behalf of customers, supporting clear and consistent processes, and reducing unnecessary delays,” the submission read.
No disadvantage by distribution channel
The submission then tackled the question of whether a customer should receive different outcomes depending on how they came into contact with a mutual.
The MFAA said that the code should enshrine principles of fairness and non‑discrimination.
“It is important for reasons of consumer protection and preserving market integrity and competition that principles of fairness and non-discrimination are enshrined, ensuring consistent customer outcomes irrespective of the channel through which a customer accesses a banking product,” the MFAA said.
The association then translated that principle into concrete expectations about pricing and product terms across channels.
“The Code should make clear that customers are not disadvantaged based on how they choose to access a banking product,” the submission noted.
“This means ensuring that equivalent products are made available on consistent terms and conditions across all distribution channels, including where customers engage through a mortgage or finance broker.”
Cyber security, privacy, and scams
The final recommendation responded to growing concern about scams and data breaches in complex lending chains that involve multiple parties holding customer information.
The MFAA emphasised the shared interest between lenders and intermediaries in protecting clients and outlined that brokers were increasingly helping customers who had encountered scam attempts during the loan process.
It said the code should spell out practical safeguards that would apply wherever data was handled.
“This could include aligning document retention requirements with statutory limits, so brokers are not required to hold sensitive information for longer than necessary,” the MFAA said.
Public consultations on the code review opened in early February, with submissions due by 2 April and a final report to be delivered to the Customer Owned Banking Association by 30 June 2026.
COBA has framed the review as a chance to refresh standards for the 5.4 million Australians who bank with mutuals, including how institutions respond to hardship, vulnerability, and digital risks.
[Related: Public consultations open on customer-owned banking code review]
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