Chapter 3Branch closures—justification, processes and impacts
3.1According to the Australian Prudential Regulation Authority (APRA), just over 2100 bank branches were closed in Australia between 2017 and 2023—almost 40percent of branches.
3.2This chapter considers the reasons that authorised deposit-taking institutions (ADIs/banks) have closed so many of their branches, how they have implemented these closures, and impacts on bank employees and their families. To frame this discussion, the chapter first looks at rules and regulations that apply to closures, including the Australian Banking Association (ABA) Branch Closure Support Protocol, which was updated in June 2023.
What are the rules?
3.3The regulatory architecture applying to Australia's banking sector is complex, including the framework that guides banks when closing branches. Drawing on evidence about the ABA's Banking Code of Practice (Banking Code), and the recently reissued Branch Closure Support Protocol (Closure Protocol), this section considers the adequacy and effectiveness of the current regime.
Banking Code of Practice
3.4The Banking Code sets standards of practice for banks. While it is industry owned and managed, and signing up is voluntary, the Code is registered with the Australian Securities and Investments Commission (ASIC) and is legally enforceable for signatories. All major banks, and a number of smaller ADIs, are signatories.
3.5The Banking Code Compliance Committee (BCCC) is an independent body responsible for monitoring ADIs compliance with the Banking Code. According to BCCC, its purpose is to 'monitor banks' compliance with their obligations under the Banking Code of Practice and drive best practice that leads to better outcomes for customers'. The Code Compliance and Monitoring Group (CCMG) is a separately funded and operated business unit of the Australian Financial Complaints Authority (AFCA). The CCMG supports BCCC in its work.
3.6Chapter 7 of the Banking Code relates to banks' commitments when closing a branch. It states that banks will:
… comply with the ABA protocol when closing a branch. The protocol outlines our commitment to provide banking services to personal, and small business customers in remote, rural and regional areas.
3.7Chapter 13 of the Code obliges signatories to provide 'inclusive banking services' and to assist 'customers who reside in remote communities (including remote Indigenous communities) to access and undertake their banking services'. It specifically commits to providing inclusive banking services for:
(a)older customers;
(b)people with a disability;
(c)Indigenous Australians, including in remote locations; and
(d)people with limited English.
3.8Chapters 14 and 15 commit banks to 'taking extra care' when dealing with vulnerable customers—including those who are aged, those experiencing cognitive decline, people at risk of domestic and family violence, and those with mental illness or serious illness—and customers with a low income. These chapters include a commitment to facilitate 'access' for those who are vulnerable, make communication 'easier', and refer people to 'external support' where appropriate.
3.9Many submitters, including those from communities affected by branch closures, highlighted these chapters of the Banking Code, and suggested regional branch closures represent a failure of the banks to meet their commitments under the Code.
3.10For instance, the Shire of Carnamah said the Banking Code 'effectively clashes with how banks close their local branches', because banks do not consider the impact on communities. Mr Michael Sanderson questioned whether regional branch closures comply with the obligation to provide 'inclusive' services and argued that '"service" will always be sacrificed by a self-regulated private corporate Banking industry on the altar of "profit"'.
3.11Another submitter said that shutting down branches all over regional Australia implies the Banking Code does not 'mean anything', and MsWebster argued that not providing face-to-face banking services is 'a breach of the Banking Code of Practice's overarching principle to provide accessible and inclusive service in a fair and ethical manner'.
Branch Closure Support Protocol
3.12Chapter 7 of the Banking Code obliges banks to comply with the ABA's Branch Closure Protocol, updated in June 2023. The Closure Protocol outlines minimum requirements that a bank must meet if closing a branch when the 'nearest Branch of the same bank brand is 10 kilometres away or more by road'.
3.13The Closure Protocol only obliges banks to 'ensure that a Nearby Face-To-Face Banking Alternative is offered' where the bank 'considers that it is commercially viable to do so'. Further, if a bank 'forms the view that this Nearby Face-To-Face Banking Alternative is no longer viable, the bank may subsequently stop this service'. Where banks do not consider the provision of nearby face-to-face banking alternative services to be commercially viable, the Closure Protocol states that 'the bank will undertake to identify other Nearby retail banking service options prior to the Branch closure and ensure that these options (if any) are communicated to Affected Customers'.
3.14In cases where the nearest branch of the same brand is greater than 10kilometres away, but less than 20 kilometres, banks are obliged to:
provide information about accessing its services and offer education and assistance to customers to access alternative channels;
'actively engage with Affected Customers and Key Local Stakeholders and respond to queries and concerns about the closure of the Branch'; and
support customers who 'face barriers to banking services', such as:
older people;
people with a disability;
First Nations people; and
people with limited English.
3.15Banks must also 'take steps to assist Affected Customers who contact the bank to help them transition to alternate banking channels' and assist 'eligible Affected Customers to open affordable banking products and services such as basic, low or no fee accounts'. Banks should also 'consider' whether customers require further assistance, such as 'interpreters', 'AUSLAN services', 'easy read or simple English communications', or 'information in languages other than English'.
3.16Further obligations apply when the nearest branch is more than 20kilometres away. In this instance, a bank must give: 12 weeks' written notice to 'key local stakeholders', if it intends to offer a nearby face-to-face banking alternative; and 24 weeks' notice, if it does not intend to offer a nearby face-to-face banking alternative. Banks must also 'prepare and publish a Branch Closure Impact Assessment [Impact Assessment] in relation to that Branch following the Branch closure announcement'. The Impact Assessment must:
(a)state reasons for the closure decision including a summary of information used to make the decision,
(b)summarise communication and engagement that the bank will undertake in relation to the closure decision,
(c)detail how Affected Customers can make enquiries regarding their ongoing banking needs, post-closure, and
(d)be published on the bank's website and physical copies available in the closing Branch.
3.17Where the nearest branch is more than 20 kilometres away, banks must also waive transfer fees if they will not provide an alternative face-to-face option, and 'consider' providing support to assist Affected Customers to transition to 'a Local Face-To-Face Banking Alternative or other banking services through third parties, such as Bank@Post'.
Concerns with the Closure Protocol
3.18A number of submitters argued that the Closure Protocol is weak or is not being complied with when banks close branches.
3.19BCCC was concerned that limiting the application of the Closure Protocol to closures outside of 10 kilometres 'creates a gap where important safeguards … do not apply', which may 'disproportionately disadvantage those customers experiencing vulnerability or with accessibility needs'. It noted that the Closure Protocol talks about the availability of alternative banking channels, but 'does not contemplate the suitability' of those options, meaning banks are 'not meeting community expectations of alternative banking channels'. BCCC argued:
Banks should consider their specific obligations under Part 4 of the Code, which commits banks to provide inclusive and accessible services, when making a decision to close a branch. One major bank told us they take a multi-channel approach to accessibility of their banking services. For example, if one channel is not accessible, another is likely to be. We recognise that multiple service channels give customers choices in the way they engage with their bank. However, we strongly advocate that each channel should be as accessible as possible.
3.20The Council on the Ageing submitted that Closure Protocol 'is only concerned with communication, often perfunctory, of branch closures rather than the closures themselves'. In support of this view, the committee notes that the impact assessment need only be published after the branch closure is announced.
3.21Ms Webster said the Closure Protocol has been 're-written so many times it offers no protection at all for vulnerable communities', and that Bank@Post gives banks 'an easy "out" … of leaving behind a face-to-face service for cash transactions without having to open up the "if commercially viable" can of worms'.
3.22Along with criticism of the Closure Protocol itself, community representatives argued banks have breached their own rules when closing branches. CatholicCare NT asserted that Westpac breached the Banking Code when closing the Tennant Creek branch:
In this instance Westpac breached the Branch Closure Protocol required under Clause 14 of the Banking Code of Practice.
No notice was given to stakeholders, community members or customers, the branch was open one day and closed the next, with no information but a sign on the door saying ‘permanently closed’.
According to Westpac, reasons for closure were insufficient staffing, leading to safety concerns.
There was no consultation with community leading up to the closure.
Westpac staff on the ground did not prepare their customers or discuss alternative options to face to face banking with them. There was no investment in resourcing and staffing the ICT or Remote Servicing to help fill the gap left by branch closure.
[At CatholicCare NT] due to Westpac Customers presenting at our office in need of help with their banking issues we had to prioritise support. This has had a critical and sustained impact on our service delivery to this day.
3.23Mr Shane Love MLA, Leader of The Nationals Western Australia, submitted that Westpac:
'did not engage with the Carnamah community' and 'ignored' requests by the Shire of Carnamah to delay the closure;
ignored the Carnamah Shire's request for an Impact Assessment; and
advised the Shire Council that customers could continue Bank@Post services at the Carnamah Post Office, but 'refused to acknowledge that the Carnamah Post office does not have disabled access'.
3.24Mid Murray Council said banks 'have failed to uphold [the Banking Code]' in rural and remote areas and are now 'forcing vulnerable and marginalised [people] to bank using methods that they do not want or do not have access to'.
Impact assessments
3.25The Closure Protocol includes a requirement for banks to produce impact assessments when closing a branch. Banks explained they are now producing these when closing branches, but inquiry participants were highly critical of the documents. This evidence is detailed below.
3.26National Australia Bank (NAB) introduced impact assessments and made them publicly available in September 2022. The bank was asked about these documents in Sale, where committee members suggested the Impact Assessment for the closure of NAB's Maffra branch was a 'desktop approach', based on statistics and data, reflecting the bank's failure to engage with the community. Mr Mil Kairouz from NAB insisted that he engages with 'local staff and communities' when making these decisions, but agreed that the staff of the branch only find out 'days before'. Committee members suggested it is an abuse of the English language to call this 'consultation'; Mr Kairouz said, 'I understand that'.
3.27In Sale, Westpac was asked if its impact assessment for Sale would include 'direct consultation' with the local community. MrMiller maintained that Westpac's process 'doesn't involve consultation with communities before the decision'.
3.28The ABA responded to suggestions that impact assessments do not provide any genuine information about the impact of a closure on the town, and that consultation should precede a closure announcement, saying the Regional Banking Taskforce 'considered and ultimately did not recommend prior community consultation of a closure decision'. The reason provided for this by the ABA was that 'bank staff must be the first to know about the decision'.
3.29Following the announcement that it will become a digital-only bank, Bankwest was asked about impact assessments for the branches that were set to close. MrCory said:
Essentially, we've made an announcement of our strategy and confirmed [our] growth plan for the transition to a digital bank. The next phase is to move directly to informing customers and communities of the individual closures, confirming the time frame of each individual closure and sharing the information about alternative ways to bank and also the branch closure impact assessment.
3.30Senators suggested that this statement confirmed impact assessments were being prepared after a decision had been made, and suggested this was not the intent of the recommendations from the Regional Banking Taskforce. Mr Cory was then asked about the status of impact assessments for branches that were set to close in coming days, including Mount Lawley and Wembley. Senators noted there were no impact assessments currently available on the Bankwest website regarding these closures.
3.31Mr Cory did not know if impact assessments had been published for these closures and took on notice the provision of draft impact assessments for all of the remaining branches that would be closed. He later noted that the two locations mentioned were metropolitan branches, and banks only have to provide impact assessments when closing regional branches.
3.32The committee Chair, Senator the Hon Matthew Canavan, tabled a copy of Bankwest's Branch Closure Impact Assessment for Kununurra. The Chair invited MrCory to comment on the adequacy of the document, noting that data provided in the assessment is 'generic', state-wide customer data. SenatorCanavan then asked Mr Cory to provide customer data for Kununurra, which he could not provide.
Figure 3.4Extract from Bankwest Branch Closure Impact Assessment for Kununurra
Source: Bankwest branch closure impact assessment, Kununurra, tabled by Senator the Hon Matthew Canavan, Chair, at a public hearing on 13 March 2024.
3.33Looking at the document, Senator Canavan asked Mr Cory to point him to any part of the assessment that has 'anything specific to Kununurra, apart from the address of the Australia Post and the address of the Commonwealth Bank ATM', and asked Mr Cory if a consultation report was prepared on the impacts of closing the branch at Kununurra:
CHAIR:… With this consultation phase, was there a report generated? Did you get a report across your desk to say: 'Here, Mr Cory; we've done it. We've gone out and spoken to these organisations, and this is what they told us'? Was that done?
Mr Cory:We receive information on a regular basis—
CHAIR:I'm asking what you received, Mr Cory. Did you receive any report? You mentioned you've got a large team doing this work. Did you receive any information from them—'This is who we spoke to in Kununurra, and this is what we think the impact will be of closing the [branch]'?
Mr Cory:We've absolutely received feedback from stakeholders in the Kununurra—
CHAIR:Mr Cory, you're not the king; you can't use the royal 'we'. I asked you: did you receive that information—yes or no?
Mr Cory:I have personally received feedback from stakeholders in relation to that decision and in relation to other decisions.
CHAIR:Was there a report done? Did you receive a written report on Kununurra in the consultation phase?
Mr Cory:I wouldn't necessarily characterise it as a formal written report, but we certainly received information from stakeholders in the community during the consultation phase and once the consultation phase was complete…
3.34The Chair suggested that Bankwest's approach to the closure indicated that the recommendations of the Regional Banking Taskforce are not being implemented and there may now be a need for 'a much stricter set of arrangements'.
Enforcement
3.35Along with their doubts as to its adequacy, a number of inquiry participants were concerned about the enforceability of the Banking Code (and the Branch Closure Protocol, which sits beneath it).
3.36The Australian Citizens Party argued that the Banking Code 'has never actually been enforced' and that the BCCC 'is governed by its ABA-designed Charter, which significantly constrains its operations':
Banks self-report tens of thousands of breaches of the Banking Code every year, without consequence. The branch closure protocol is supposedly enshrined in the 'enforceable' Banking Code, yet banks have continually breached the protocol with no action from the BCCC.
3.37Ms Webster said the BCCC 'has been criticised in the past for being toothless', but acknowledged that it has highlighted possible breaches of 'part four of the code, which relates to inclusive and accessible banking, and the impact of branch closures are having in particular on Aboriginal and Torres Strait Islander communities'.
3.38The BCCC argued that its 'independent oversight of compliance with the Protocol is critical to driving improved practice'. According to the BCCC, there has been 'an increase in concerns' raised about branch closures, including in communities with large numbers of Indigenous customers. Complaints received by the BCCC have been around issues such as:
the impacts on the community in the event that there is not the normal notice/transition period outlined in the Protocol (due to reliance on an exemption);
the lack of appropriate transition arrangements to support affected customers;
the inadequate servicing or closure of the bank's ATM, which impacts elderly customers who utilise the cashless card withdrawal service at the bank's ATM; and
the lack of preparedness of alternative banking channels, including the capacity of the bank’s call centre.
3.39BCCC concluded that banks 'must ensure they have adequate oversight, systems and processes to comply with the Code for banking services offered by alternative providers, including Bank@Post'.
Banking Code Review
3.40The ABA drafted a revised Banking Code following an independent review in 2021. The revised Code has been submitted to ASIC for approval. On17November2023, ASIC opened a public consultation on the revised Code, seeking submissions. The consultation closed in January 2024 and ASIC has yet to release its response.
3.41According to the BCCC, there is 'consensus on the need to strengthen the [Branch Closure Support] Protocol to ensure the thresholds and relevant considerations and expectations when closing a branch remain appropriate'. The BCCC said banks should 'be proactive and progressive in meeting their promise in the Code … to provide inclusive and accessible banking services'.
3.42As part of the review, the BCCC suggested that the ABA should consider 'practices for assessing customer needs and providing alternatives' outlined in the United Kingdom Financial Conduct Authority's publication on Branch and ATM closures or conversions.
3.43Chapter 4 of this report considers options for strengthening the Banking Code and Closure Protocol and Chapter 5 includes the committee's recommendations.
Reasons for branch closures
3.44A number of factors influence the decision of financial institutions to close or maintain bank branches. The key factors cited by major banks were:
changes in customer behaviour and preferences—in particular, a reduction in foot-traffic as customers move to online, telephone, video and mobile banking;
the need to redirect investment to digital banking architecture, services and development; and
difficulties in staffing and maintaining regional branches.
3.45Banks provided statistics and data to support their reasoning. However, some inquiry participants disputed the banks' assertions, questioned the data, and provided alternative viewpoints.
3.46In this section, the committee considers evidence from the major banks, other financial institutions such as customer-controlled banks, bank staff and unions, customers, and representatives from affected communities.
Evidence from banks
3.47During the inquiry, major banks argued that closing branches has been necessary and unavoidable because customers have shifted their banking from face-to-face to digital channels.
The shift to digital
3.48Mr Matt Comyn, Chief Executive Officer (CEO) of Commonwealth Bank of Australia (CBA), said the bank has had to close branches because 'the way customers engage with banks continues to change'. NAB said over the counter (OTC) transactions in NAB branches have decreased by 70 per cent since 2015. Westpac submitted that its branches have seen a 45 per cent decline in OTC transactions over the five years from 2018 to 2022, with regional branches recording a slightly smaller decline of 39 per cent.
3.49NAB observed that this trend is not 'unique to banking', with a similar shift taking place in how Australians shop, study, work, and interact with government services. Mr Ross Miller, Chief Customer Engagement Officer, Westpac, highlighted the role that the pandemic played in accelerating this shift, and NAB asserted that this change is a result of customer preferences—including rural and regional customers.
3.50Mr Miller said Westpac's move to 'Digital First banking' is a direct response to customer preferences and behaviours, as customers now want to 'do their banking at any hour of the day from the comfort of their own home'. This view was echoed by Ms Anna Bligh, CEO of ABA, who said 'Australia's banks are undergoing an extraordinary customer-led digital transformation'.
3.51The move to digital banking has created new challenges, and new areas where banks must invest, including in 'improving and securing the digital services'. MrMiller said Westpac is investing 'hundreds of millions in technology', and Mr Comyn reported that CBA invests 'about $750 million per annum [to prevent] cyberfraud, scams protection and financial crime'.
3.52While they relied heavily on data showing over 95 per cent of transactions are now conducted via digital channels, major banks acknowledged that not all customers want to, or are able to bank online. Mr Miller also agreed that branch closures can disproportionately affect regional communities:
We recognise that not all customers are ready to move to digital banking. For a small minority going into a bank branch is still preferred or necessary. This means that, while there are fewer people using our branches, the absence of one can still have a significant impact on some. While the reduction in branches is something that has occurred across the entire sector, we recognise that in regional areas the impact is felt more.
3.53Westpac argued its closures have been 'skewed towards metropolitan areas', saying, from 1 July 2017 to 30 June 2022, Westpac closed 283 branches—83percent (235) were in metropolitan areas, while 17 per cent (48) were in regional areas. Similarly, Mr Comyn said CBA has 'chosen to skew closures towards metropolitan areas'. Despite the fact that around 40per cent of CBA's branches are located in regional areas, the bank asserted that 'regional Australia only accounted for 25 per cent of closures over the past four years'.
3.54On 6 March 2024, Bankwest—a subsidiary of CBA—announced that it would close or convert all of its remaining branches and become a digital-only banking service. This meant the closure of 45 branches in Western Australia, and the conversion of 15 regional Bankwest branches to CBA branches.
3.55Bankwest representatives argued this decision was justified, as 'branches now average around 30 over-the-counter transactions per day and 15 in regional [Western Australia]'. However, when asked to comment on evidence that Bankwest has been actively migrating its customers to digital channels since at least 2020, General Manager of Personal Banking, Mr Scott Spittles said, ' I think it's fair to say that Bankwest has been on a pathway towards growing as a digital and broker-first bank for homebuyers for a considerable period now'.
Other reasons
3.56Some banks cited additional aspects of customer behaviour, and other external factors, as influential in their decision to close a branch. NAB argued that many customers in smaller regional towns prefer to bank in large regional centres, where they can also attend appointments or go shopping. The NAB branch in Forbes, New South Wales was closed for this reason, with NAB saying 75 per cent of Forbes customers were already banking in neighbouring Parkes.
3.57CEO of the Australia and New Zealand Banking Group Ltd (ANZ), MrShayneElliott, said the bank would 'love people to use the branches' and tries 'to extend their life'. According to Mr Elliott the process of closing a branch is 'difficult, complex, and opaque', and a number of factors weigh in, such as:
Who is in the branch? What are they doing? What are the future prospects of the town? Are there new things happening in the town? What are our obligations? Our history in a place is part of the decision. Do we own the building? Do we lease it? What is the landlord thinking about? Do we have access to staff? All of those things come into the mix.
3.58Another reason cited was the 'stickiness' of bank customers. NAB and CBA both confirmed that over 90 per cent of customers remain with the bank after their branch closes. CEO of Wellington Shire Council, MrDavidMorcome, said councillors in regions affected by closures 'suspect' that the 'extraordinary level of resistance that [regional] communities have to actually switching banks' factors into banks' decision to close branches.
Closure metrics
3.59Committee members were interested in understanding exactly which metrics, data, demographic, and other considerations banks rely upon when making closure decisions.
3.60While most banks cited a reduction in branch visitation as the primary factor in the decision to close a branch, Westpac and NAB insisted the decision is not made simply on statistics. Ms Krissie Jones from NAB maintained that closures are 'not done lightly', with many variables factored in, including the cost of moving cash and difficulties finding staff. Mr Miller said Westpac considers 'branch usage, customer demographics, location and proximity to other banking services, particularly our Bank@Post partnership service'.
3.61Mr Miller claimed Westpac employs a 'rigorous process' when deciding to close a branch, with the 'most important' consideration being 'branch usage', including the 'types of transactions' customers are completing in the branch. However, when asked if there are 'particular benchmarks that are quantifiable' used in making these decisions, Mr Miller said 'yes', adding:
… it's not just a single isolated metric; we look within that metric as well. ... Initially, low customer usage would be an indicator for us, but then we'd look at the types of transactions those customers are using the branch for and look at what are the alternative solutions for customers in that area so that we can invest in improving the channels where customers were previously using the branch and they're now using elsewhere. We don't look simply at customer usage. We then look at the types of transactions they're using and we come up with a recommendation based on that.
3.62Banks were asked if they measure the 'profitability' of individual branches when making closure decisions. Mr Comyn acknowledged that 'profitability is important'. However, CBA does not 'keep individual profit and loss statements' for branches, as it is no longer possible to measure the contribution of specific branches at a 'granular' level. Mr King said Westpac 'used to measure branch profitability and tag all the customers and their revenue to [a] branch', but this is no longer the case. Mr Miller said Westpac runs 'adistributed business', with 'service channels … distributed nationally' and, while the bank may consider 'regional performance', this is 'not hardwired to a branch'.
3.63Evidence from banks suggested a key consideration in closing branches was whether or not regular customers could be served by Bank@Post. Commenting on the closure of the Coober Pedy branch, Westpac said, that while '372 customers completed on average 1009transactionspermonth' (6–8 transactions per hour), there were only four customers whose 'needs' could not be met through Bank@Post.
3.64Committee members looked at Westpac's decision to close eight regional branches based on a reported reduction in customer activity. Westpac was asked to explain why it had identified the eight regional branches for closure, and not, for instance, the Parliament House Westpac branch. On notice, Westpac provided the following data on customer usage:
Sale, VIC—customer usage down 22 per cent on FY20H1
Tully, QLD—customer usage down by 30 per cent on FY20H1
Cloncurry, QLD—customer usage down by 41 per cent on FY20H1
Ingham, QLD—customer usage down by 20 per cent on FY20H1
Denmark, WA—customer usage down by 35 per cent on FY20H1
Gatton, QLD—customer usage down by 11 per cent on FY20H1
Robinvale, VIC—customer usage down by 41 per cent on FY20H1
Kingston SE, SA—customer usage down by 19 per cent on FY20H1
Parliament House, ACT—customer usage down by 26 per cent on FY20H1.
3.65Noting the reduction in customer usage at the Parliament House branch is higher than some of the branches being closed, Westpac submitted that it had 'made the decision to launch new services in the branch' (rather than closing it).
'Transactions' versus 'visits'
3.66There was some confusion and debate during the inquiry around the banks' use of 'transaction data' to show dropping branch utilisation. The committee noted that branch data seems to only quantify specific banking transactions. For instance, NAB's branch closure fact sheets provide the figures for personal cash withdrawals, personal cash deposits, personal cheque deposits, business deposits, and business cheque deposits. They also quantify the numbers of customers who are 'regular' and 'heavy' users of the branch, as seen in the figure below:
Figure 3.1NAB Alexandra closure fact sheet: How are customers using this branch?
Source: NAB, response to questions taken on notice, 20 September 2023 and written questions from Senator the Hon Matthew Canavan (received 5 October 2023), [p. 6].
3.67Committee members asked NAB to respond to suggestions that this publicly reported branch usage data fails to capture 'general business', such as customer queries around technology, proving your identity, changing a name on an account, and other non‑transaction services. NAB confirmed this, with Ms Jones saying the '[OTC] transactions are what we include in our closure FAQ sheets, but that's not the only data that we look at' [when considering whether to close a branch]. Bankwest explained that its data on 'digital verses non-digital transactions' similarly excludes 'service interactions'.
3.68ABA provided data showing the decline in 'branch visitations' from 2019 to 2023, as seen in figure 3.2. While the data appears to enumerate transactions only, the terms 'branch visitations' and '[OTC] transactions' are used interchangeably in the document:
Figure 3.2OTC transactions at regional branches, Financial Years 2019, 2022 and 2023
Source: ABA, response to questions taken on notice, 20September 2023 (received 10 October 2023), [p. 2].
Data from: ABA member banks–ANZ, Bendigo & Adelaide, CBA, NAB, Suncorp, Westpac; Analysis by ABA.
3.69Committee members suggested that communities would be interested in data on all branch visits, not just transactions, and asked banks if they collect this information.
3.70NAB confirmed that, while it does not report on service interactions when closing a branch, itdoes collect the data. MsJones said NAB collects statistics on 'account openings and on account closures … the number of balance inquiries and the range of different types of reasons for why a customer would come into a branch'. However, the bank does not include these in its 'visitation statistics' because it believes OTC transactions are the 'most relatable' information. MsRachel Slade, Group Executive Personal Banking, NAB, added that transactions represent 'the vast majority of activity that takes place', and Mr Ross McEwan, Group Chief Executive Officer and Managing Director, NAB, said transactions account for 'probably 90 per cent of what goes on'.
3.71According to Ms Slade, a number of other customer interactions are not even collected, as they are 'incredibly difficult to measure', and banks do not have 'systems and processes' to measure them. These include things like 'a customer coming in to report a fraud or a scam'.
Keeping branches open—evidence from customer owned banks
Box 3.1 Keeping regional branches open [O]ur banks work to find solutions where most would walk away. In recent months, Hume Bank has opened a branch in Holbrook, a town of 2000 people, near the New South Wales and Victorian border; Horizon Bank has opened up a branch in Berry, a town of 5000 people; Heritage Bank has joint ventures with local communities in regional Queensland; and the Capricornian have partnered with local government to keep branches open in Northern Australia.—MrMichaelLawrence, CEO, Customer Owned Banking Association. |
3.72Customer owned banks are also known as mutual banks, credit unions and building societies. They are owned by customers, who are members of the bank. In general, profits made are 'reinvested into better products and services for members, instead of being distributed to investors'. Despite holding only 10percent of household deposits, the sector collectively operates 720branches—the third largest branch footprint after CBA and Westpac.
3.73The Customer Owned Banking Association (COBA) represents 56 customer owned banks, with around five million customers. Incontrast to evidence provided by the major banks, CEO of COBA, MrMichaelLawrence, said:
… our regional members understand the needs of communities across the country because that is where they live. More than half of our sector's employees, from the CEO to the branch staff, live and work in regional Australia. More than half of our members are headquartered outside of metropolitan Australia, in places such as Toowoomba, Armidale and Wodonga.
3.74Customer owned banks have a disproportionate 'regional branch presence', and operate more branches for their size than the major banks:
For every billion in assets, customer-owned banks operate four branches, compared to 0.6 of the major banks. To put this into context, that means we operate 18 per cent of branches nationally, with only 3.5 per cent of total asset market share. The proportion is even higher when you look at regional Australia, where customer-owned banks operate 21 per cent of branches. This is a direct result of the mutual model, where we put customers at its core.
3.75According to COBA's submission, customer owned banks operate 347 regional branches (one in every five), placing them above CBA, which operates 311 regional branches (2022 APRA data).
3.76COBA submitted that its members have closed less than half as many regional branches since 2017, compared with all ADIs:
Figure 3.3Regional branch closures from June 2017 to June 2022—all ADIs verses customer owned banks
Source: COBA, response to question taken on notice, 20September 2023, [p. 1].
3.77Data on branch usage provided by customer owned banks contrasted with the figures provided by major banks, generally suggesting customers still use these branches. Hume Bank, for instance, submitted that 47 per cent of its customers have used the bank's branches in the past six months; of those customers, 79percent also used digital services, and 21 per cent exclusively used branches.
3.78Some customer owned banks are even opening new branches in regional Australia. Hume Bank said it is partnering with local councils and communities to set up new branches as the big banks leave. Referring to Hume Bank's new branch in Holbrook, Chief Operating Officer (COO) of COBA, MsStephanieElliott, said COBA is 'very hopeful that the community will support them'.
3.79COBA acknowledged there are costs and challenges associated with maintaining regional branches, including:
the need to also provide online services;
the cost of investing in digital infrastructure and services;
the stickiness of major bank customers;
people using their members' branches to deposit cash, then transferring the money to another bank (banking 'through' them, not 'with' them);
the increasing cost of moving cash; and
the impact of what Mr Lawrence called 'poorly timed and coordinated regulation and regulatory action'.
3.80Rather than simply closing underutilised branches, many customer owned banks have worked to implement innovative strategies to stay open, including reducing opening hours, deploying mobile lending services, and directing branch staff to handle phone inquiries and 'centralised tasks' for the broader bank network.
Community partnerships
3.81According to COBA, customer owned banks have 'entered into partnerships to keep branches open' and open new branches in underserviced communities. Examples include the Queensland-based credit union, TheCapricornian, which opened a branch in Capella—a community of only 1000 people—in 2021. This was made possible by partnering with the local council who hosted the branch within council buildings.
3.82Another example is Heritage Bank, based in Toowoomba, which operates seven community branches in regional locations. The Heritage Bank model sees community members form a joint venture with the bank to stand up a local branch. Once the bank's initial investment is repaid, the branch 'becomes a true Community branch', reinvesting profits into the community.
3.83While this model has proven successful, it requires initial startup funds of around $500000, which 'can be prohibitive' for communities to raise. COBA suggested governments could consider providing interest free loans to support communities with these initial costs.
3.84With major banks leaving many communities, customer owned banks provide an alternative. However, Mr Lawrence argued the 'complexity of regulation' in the modern banking sector acts as 'somewhat of a barrier for new entrants'. COBA called upon the committee to support customer owned banks by 'ensuring that its own recommendations are proportionate and targeted, and by recommending that government adopt a regulatory road map'.
Evidence from communities and bank staff
3.85Other inquiry participants questioned the rationale offered by the major banks. Community representatives, including local councillors, argued it is manipulative of the banks to suggest that closures are driven by customer preference, rather than commercial imperatives. Unions and bank employees described the reasons provided by banks as 'disingenuous', and reported that banks are, in fact, driving customer behaviour by 'pushing' customers online.
3.86MrDavid Anderson, Chairperson, Committee for Wellington said:
A decision to close a branch is driven by economics more so than a change of behaviour, and, by stating a change in behaviour as a basis, the banks are effectively blaming the customer for closure. It's the introduction of technology by banks that has driven a change in customer behaviour, and it does feel a little like manipulation.[78]
Commercial imperatives
3.87Mayor of East Gippsland Shire Council, Mr Mark Reeves, disputed the idea that people in regional communities are happy with digital services, and maintained that the banks have failed to ask them. According to Mr Reeves, his community 'wants physical services', so this is something the council continues to provide. Mr Reeves suggested the cost of providing face-to-face services can be seen as 'investment' in the community.
3.88Representatives of local councils argued banks are closing branches for 'commercial' reasons. Mr Reeves said this behaviour is out of place in regional Australia, where 'businesses have a social conscience and contribute to sporting clubs and voluntary organisations'. Chairperson of the Committee for Wellington, Mr David Anderson agreed, asking 'where is the moral obligation to support regional communities?' Mr Andersonadded:
There is an expectation that the corporates of the world are to be involved in their respective communities and are more than just a bank. They're a contributor. They're a sponsor of the local footy team. The banks have had the pleasure of our communities supporting them through the use of their institutions, they've had the pleasure of the use of our money and they've had the pleasure of making extremely healthy profits from our money. Itremains unclear as to why closure is warranted.
3.89Banks were asked to outline their views on whether or not they have a responsibility to regional and remote Australia. ANZ replied to this question on notice, saying the bank 'attempt[s] to meet community expectations by acting in accordance with the law and working to balance the interests of our stakeholders, which include our customers, staff and shareholders'.
3.90Mr Miller's response suggested that Westpac considers its partnership with Australia Post to be fulfilling its obligation to provide services for regional customers:
Choosing to partner with Australia Post, which is also a government organisation, is one of the ways we'll provide services going forward. We know they have the strength of 3,500 locations across Australia where our customers will be able to bank.
3.91NAB submitted that it 'endeavours' to provide a 'Community Banker' when it closes a regional branch:
The Community Banker is a NAB employee who is based at a post office close to the closing branch, for one day per week, for a brief period following the closure of the branch. The Community Banker assists customers who would like to use Bank@Post, to transition to this service. There has been a small number of locations where NAB has been unable to provide a Community Banker, as the post office licensee has not consented to NAB providing this service at their outlet.
3.92In contrast, Mr Comyn's evidence suggested CBA does acknowledge that the bank has a broader social or national responsibility. He said CBA is 'very conscious of [its] obligations with [its] customers and the broader community and the history and the future of Australia'. Mr Comyn highlighted CBA's commitment to regional Australia and said 'social licence obligations' feed into the bank's decision-making.
3.93The issues of banks' social licence and community service obligations are further considered in Chapter 5 of this report.
Pushing customers towards digital channels
3.94Bank employees and unions said a number of banks, including Westpac and NAB, have implemented deliberate strategies and policies to 'push' customers online and away from face-to-face services. Ms Wendy Streets from the Finance Sector Union (FSU) said:
The banks claim that the public prefer to complete their financial transactions online. However, it is disingenuous for the banks to single out their customers as the reason for these closures. It is the banks that have enforced this change. It has long been part of the business model of all of these banks. The banks have engineered the move to digital and herded their customers into these options.
3.95Ms Streets reported that bank staff have had 'targets imposed on them to convert customers to digital banking'. Staff have told the union that banks impose limits on the number of OTC transactions, and targets for opening new online-only banking accounts: 'So, effectively, workers have been made to participate in the demise of their own jobs'.
3.96According to Ms Streets, bank management regularly task retail staff with 'transferring their customers to a digital line'; managers then monitor OTC transactions and may impose disciplinary measures if staff fail to meet targets. In one example, a staff member was cautioned for accepting a credit card payment over the counter, rather than taking the customer out to the automatic teller machine to complete the task. Even where customers resist and show no interest in shifting their practices, bank staff are expected to continue to push them.
Box 3.2 Compelled to push customers into digital banking During my tenure with the NAB bank, I had to migrate a predetermined number of customers to online banking each month, whether they wanted it or not. As you can imagine, this became harder and harder to do, as the tech savvy pool of customers transitioned, leaving only those who, for the reasons I've already specified, wanted the personal service and support provided by trained branch staff. I always took great pride in helping people solve their problems and felt I was providing a valuable community service. The not-so-hidden agenda about using concierges to shepherd customers away from the counter and onto the ATM or internet banking kiosk has always been to reduce the number of staff assisted transactions. This self‑fulfilling prophecy can then be used as a justification to amalgamate some branches, reduce bank opening hours and close others.—MsMyrnaEllery, former bank employee.[88] |
3.97Current and former bank employees said management implemented practices like installing iPads in the branch and having staff redirect customers to do their banking on the iPad. These witnesses suggested that this would skew the branch statistics, as those transactions would not be counted towards visitation metrics for that branch. Witnesses also said they were discouraged from opening new accounts through the branch.
3.98Major banks responded to these suggestions in different ways. Mr Elliott said ANZ staff are not incentivised to push customers away from branches. However, staff are encouraged to show customers that there are 'alternatives'. In contrast, Ms Jones acknowledged bthat NAB has previously had such targets in place, but these were removed towards the end of 2023:
What we ask our teams to do is to offer options to our customers, such as those that I talked about earlier. We want to make sure—this was particularly relevant during lockdowns—that customers have options available to them. So we have had goals for our team on a balanced scorecard to make sure that they're offering customers different options but, from 1 October, we are removing those from our performance stats.
3.99Mr Miller did not deny that Westpac incentivised staff to encourage customers to move to using digital channels. Instead, he reiterated his view that customers prefer to bank online, and said:
What we've done throughout recent years is ensure that we're equipping our people to be able to coach and support our customers as they adopt digital banking. We do that so that, when people come into a branch, particularly if they've had to travel to a branch and it would have been more convenient for them to do something themselves remotely—we think it's not only our obligation, it's a customer service positive—we're able to show and educate people how to use our digital services.
3.100However, Ms Streets criticised this rhetoric, saying:
[The banks] endlessly repeat their talking points, without acknowledging that these are commercial decisions to boost profits and without acknowledging the harm they are doing to thousands of communities and the people who lose their jobs.
How are branches being closed?
3.101The way in which banks have gone about closing their branches was a major concern for inquiry participants. Bank staff, customers, small business representatives, concerned citizens, and stakeholders from affected communities universally told the committee that closures have come without warning and without meaningful consultation.
3.102The Hon. Bruce Billson, Ombudsman, Australian Small Business and Family Enterprise Ombudsman (ASBFEO), said:
The bank, really, is doing nothing more than being like a driver putting on an indicator light to change lanes after it has already moved. It's insulting to small- and family-business customers. This is a commentary on a closure, not an opportunity to consult.
3.103Kingston District Council explained that the announcement that the local BankSA branch was to be closed 'sent shockwaves through [the] community'. Still recovering from the 2019–2020 Black Summer bushfires, Kingston District Council said the announcement created 'uncertainty and destabilisation during a time when [the] community is exhausted and need[ed] time to heal and recover'.
3.104The Council held a public forum to discuss the closure and reported that people felt 'frustrated', 'stressed and panicked', 'undervalued', 'angry' and 'sad'. People expressed disappointment and shock, and said they felt 'gutted' and 'kicked in the guts'. Attendees were also concerned about the impact the closure would have on the community and local business.
3.105At most of the committee's regional hearings, it heard similar evidence from communities. This evidence contrasted markedly with the banks' evidence.
Lack of consultation
3.106Mr Reeves said local councils are simply 'advised the banks are closing' and are not consulted on alternative banking options for the community. MrMorcome offered similar evidence, describing Westpac's closure announcement for the Sale branch:
We received a letter on the Monday, and we opened the paper on Tuesday to see that the announcement had been made. There was a paragraph in there from a Westpac spokesperson saying they had consulted with the local shire. That's what happened in relation to Westpac's consultation. 'Consultation' from our perspective is generally how many days prior to the announcement of the closure we get advised, and usually it's only one, two or three days at the most.
3.107Kingston District Council described the bank's communication as 'very impersonal', saying it was clear there were 'pre-determined solutions in place' and that the 'decision had been made long ago'. Even though the BankSA branch was located immediately next door to the Council, the closure letter was emailed and incorrectly addressed:
We were notified by email, to our generic email address, in correspondence addressed to 'Mr Bean' that the local BankSA branch would close in May this year. We certainly have no 'Mr Bean' working here—the fact that they couldn't even get the salutation to such an important item of correspondence correct speaks volumes about the bank closure process.
3.108The Council, which is also a customer of BankSA, did not even receive a 'courtesy phone call'.
3.109CEO of Latrobe City Council, Mr Steven Piasente, described closures in that region:
The notification that they were closing was provided but there wasn't a process of engagement upfront to talk about whether that should or should not occur, or whether there were other options that were available. So it's really just that the closures have been communicated to us and the community, and then they've occurred.
3.110Commenting on the treatment of employees, Ms Streets said branch staff are not consulted at all about the decision to close the branch where they work, and are only told a week (or less) before customers and the community.
3.111Independent journalist, Ms Dale Webster, said banks 'make no announcements and are not required to inform the government or banking regulator' when they close a branch.
Box 3.3 Case study—Westpac's closure at Tennant Creek In early September 2022 the Westpac Bank closed their branch in the regional NT town of Tennant Creek. The branch was closed with minimal notice and no consultation with the community. Customers were not sent correspondence advising of the branch closure and there was no transition period to help customers adjust. The majority of Westpac customers in the Barkly region are Indigenous, are older and English is their second or third language. As a result of the sudden branch closure, these customers were forced to use digital banking platforms without having the technology, security or know-how. Westpac advised that alternative pathways to banking would be the Indigenous Connect Team (ICT), which is a phone service, and Bank@Post. As described below, these options are problematic and not viable. At the time of the closure Westpac promised to maintain an ATM presence in the town. They later reneged on this promise. … after the closure of the bank, our service was inundated with First Nations people requiring assistance. Since then, we have been helping 20 to 30 people a day with their banking. We needed to pull staff from other programs in order to respond to demand. In response to these issues, Westpac said they would put a staff member into our office for a couple of months, described as 'remote servicing'. The branch closed on 13th September 2022. In fact, it was not until just over a month later, on 24th October 2022 that remote servicing began. It was only in place for a month, until Friday 19th November 2022. —CatholicCare NT. |
Bank responses
3.112While their public material often includes references to 'consultation', the major banks all acknowledged that their closure processes do not include conducting any community consultation prior to the closure announcement. None of the major banks consult the community or the staff of the branch before making the decision to close that branch. Consultation may occur after a closure and is generally focused on helping the community adjust.
3.113Ms Jones said NAB executives consult with 'internal people', some of whom may live in the broader area, and that NAB listens to its 'own team members around what the nuance is for each location'. When describing the closure of its Waroona branch, NAB submitted that the decision was made by 'NAB's senior leaders in Western Australia and other key internal stakeholders' (emphasis added).
3.114ANZ's Mr Elliott said closing a branch is not a decision he makes: 'We don't sit here in Collins Street in Melbourne and make those decisions; it would be inappropriate. We rely on our people on the ground, out in the field, to do that. These decisions can take years'.
3.115Westpac confirmed that it 'does not consult the community when it makes a commercial decision' (such as when reducing branch hours), and suggested this is not something 'any company, industry or Government service' does. When asked how Westpac knows what the community thinks about a closure if it does not ask anyone, Mr Miller replied that he has 'a very experienced team … able to give [him] any local insights that are particularly relevant'.
3.116Conversely, Bankwest said it had consulted widely around its decision to become a digital-only bank, including with 'peak advocacy bodies, such as the Council on the Ageing, Advocare, the Western Australian Council of Social Service and the [Financial Counsellors' Association]', and had also taken on board evidence from the committee's inquiry. The bank met with a number of local councils, including the Shire of Narrogin, the Shire of Wagin, the Shire of Corrigin, the Shire of Carnarvon, the City of Bunbury, and 'stakeholders in the Collie region.
3.117However, when asked to respond to suggestions that this consultation was not about the decision to close branches, Mr Spittles agreed these discussions were primarily about 'how we support the community in absence of a physical branch footprint'. The discussions also fed into Bankwest's decision to seek to convert a number of regional branches to CBA, rather than closing them outright.
What stakeholders want
3.118Community representatives and bank workers told the committee they wanted a chance to genuinely consult with the bank before a decision is made to close the branch.
3.119Ms Streets said banks need to implement:
An appeal and right-of-review mechanism … providing customers and stakeholders with the right to appeal based on fair and impartial process, clear guidelines, accessible information, opportunity to provide evidence, timely decision-making and confidentiality. Additionally, a right to review could be implemented so that, when a regional community is suffering because whatever arrangements the bank put in place before exiting the town aren't working or have collapsed, that community can ask for a review that brings the relevant parties back for further consultation and a fix.
3.120TheHonBruceBillson argued communities should be given an opportunity to 'influence the decision or perhaps shift their business to the last bank in town to encourage it to stay'. Timely consultation would provide an opportunity for local councils and businesses to 'bring the business that's in that community to that outlet'.
Impact on bank employees and their families
3.121Inquiry participants told the committee that regional branch closures can have devasting impacts on branch employees, many of whom have worked at the bank for years and are members of the community.
Box 3.4 Inadequate support—FSU example It was a regional branch in Queensland. The regional manager drove out to that branch and told the manager, who was the only permanent staff member left in that branch—they were sending casuals each day—that the branch was going to close. That regional manager never came back until the day it closed. For three months that branch manager didn't see that regional manager again. She was faced with having to have every single conversation with the customers. She has lived in that town her entire life. She had to start getting her husband to go to the grocery shop because it was too stressful for her. She had it all day at work, and then, when she went to do the groceries after work, people were coming up to her and crying because they were losing their last bank in town. We ended up with that member on a WorkCover claim. She closed the branch. She did her job, but under such duress, and the bank provided no support for her—absolutely none. Hence there is a WorkCover claim now. The first certificate she got from her doctor on the day after closure was an eight-week certificate, which is almost unheard of. Usually they stop at four weeks in the first instance. Their support is woeful. —Ms Streets, FSU. |
3.122The FSU believes that, since 2016, there have been at least 2000 job losses as a result of regional branch closures. Ms Streets said the FSU does not have 'the figure on how many have been redeployed'.
3.123Kingston District Council described its concern for staff and their families:
They are local people, with families who have lived here long term, who's [sic] kids go to school here, they shop here and are an integral part of our local community and sporting groups. There are genuine welfare concerns for these staff, but also the gap that will be left behind as they and their families are forced to move away from their community to seek alternative work.
3.124Banks told the committee that they value their staff and work hard to find ways to retain them. NAB submitted that, when a branch closes, 'all impacted colleagues are offered ongoing employment with NAB', and 97 per cent remain employed by NAB in new roles. This may mean relocating to a different branch, or taking up a different role that allows for remote work. According to NAB, the three per cent of staff who do not remain employed by NAB after a branch closure 'have chosen to leave NAB of their own accord'.
3.125Westpac said it has 'successfully redeployed 48 per cent' of affected employees into other roles, and 23 per cent have been retrenched. The remaining staff are 'still in redeployment and looking for opportunities'.
3.126Along with statistics, banks provided examples of staff who had successfully redeployed. In contrast, the FSU claimed staff are subject to 'extreme pressure' when a branch is closed. Staff are offered call centre work, often to be conducted from their home. The work offered is 'not always suitable' and workers may not have an appropriate space. Still, they are pressured to accept this work, or to resign.
3.127Another issue is that work offered to staff is not always equivalent to the work they were hired to do, or are qualified for. Current and former bank employees who gave evidence in camera talked about the stress of call centre work, the loss of personal interactions and the loss of connection to their communities. MsEllery explained that when she worked in a branch she 'always took great pride in helping people solve their problems and felt [she] was providing a valuable community service'.
Committee view
3.128Banks have claimed to this committee that reduced demand for face-to-face services means that maintaining branches becomes a net cost to the bank. There is a financial advantage for banks to consolidate and reduce their branch footprint, redirecting funds towards their digital service channels. At the same time, it is not exactly clear how a bank decides that a branch is no longer worth supporting, given all of its branches come at some net cost to maintain.
3.129In addition, banks have not fully acknowledged their own role in pushing customers towards digital channels, despite evidence that this has been a deliberate policy for many banks.
3.130The 'stickiness' of bank customers means banks rarely face a hit to their bottom line from closing a branch, despite causing dissatisfaction in the community and disadvantaging vulnerable customers.
3.131Throughout the inquiry, the committee has visited numerous towns affected by closures, and has heard story after story of disorganised, piecemeal communication efforts from the banks. Banks have failed to speak directly to local councils and other key stakeholders, even when the Council is located next door or is a customer of that bank.
3.132The committee is strongly of the view that this is simply not good enough.
3.133There is no genuine consultation, and no attempt to measure the impact a closure will have on the community. Local councils and businesses are not provided with any opportunities to negotiate to keep the branch, or with sufficient notice to find another solution for their town.
3.134The frustration felt by those in affected communities, including branch staff, is exacerbated by the banks' disrespectful treatment and failure to meaningfully engage with communities, customers, and staff alike.
3.135Australia's banks promote themselves as critical partners in the community, such as through sponsoring community programs. However, they universally fail to properly engage when a decision is made to leave a location. This represents a failure of their responsibilities to regional Australia.
3.136As outlined in Chapter 2, the bank is often at the heart of a community's business and economic activity. The loss of a town's bank has both pragmatic and psychological consequences: it disadvantages residents and dents the town's confidence.
3.137Despite their evidence that they do not 'take these decisions lightly', banks are clearly failing to comprehend, and take responsibility for, the impact of closures on communities.
3.138Branch closure impact assessments—now provided by banks as an outcome of the Regional Banking Taskforce—represent a disappointing, 'tick-a-box' exercise, and are an inadequate reflection of the impacts of closures on communities. The committee believes that many of these so-called 'assessments' are being prepared after a decision has been taken or announced, and in some cases, after the branch has closed.
3.139These documents should demonstrate genuine engagement with both customers and stakeholders in affected communities. They should include meaningful branch-specific data, which captures the full picture of the use of the branch. They should acknowledge if the branch closing is the last bank branch left in a town, and should outline all alternative banking options—including the option to switch banks.
3.140The committee believes the Banking Code, Branch Closure Support Protocol, and associated regulatory structures, need to be changed. The current system of self-regulation is leaving regional Australia high and dry as banks continue to make closure decisions with little regard for the damage caused.
3.141Further regulation is needed to clarify the responsibilities and obligations of banks to regional communities, hold them to account for their closure decisions, and ensure that banks consult and engage in a genuine and meaningful way.
3.142Proposed regulatory reforms and other suggested solutions are outlined and considered in the next chapter of this report.