As has been widely reported, The Royal Commission into Misconduct in the Banking, Superannuation and Financial Services Industry (“ the Hayne Royal Commission”) released its Final Report on 4 February 2019. 

The Royal Commission’s Final Report contained 17 recommendations for the banking sector and 3 cross-sectoral recommendations on “culture, governance and remuneration”. Of greatest impact on ADIs to date have been: (1) the extension of the BEAR regime to broader areas within ADIs; and (2) the revisions to the Banking Code, which imposes additional requirements on ADIs.

At a Glance

Hayne Commission Final Report

In Gen Advisory's view, Commissioner Hayne has produced a comprehensive and well-written Final Report. Perhaps inevitably, however, the much-dissected Final Report has satisfied certain groups but not all.  There are some - Gen Advisory included - who feel that the Report falls short of major structural reform.


Additionally, Gen Advisory respectfully disagrees with some of Commissioner Hayne's observations in relation to the banking sector, 

Notwithstanding these criticisms, Gen Advisory’s overall conclusion is that the Final Report has merit. It provides ADIs with a series of practical recommendations which, if implemented successfully, will ultimately strengthen the Australian banking sector.

Our Analysis

What Is It

The Final Report contained: 

  • 17 banking-specific recommendations and 

  • 3 cross-sectoral recommendations on “culture, governance and remuneration”.

The Future

Likely impacts:

  • Greater focus on “CGRA” risks.

  • More litigious enforcement approach by ASIC and APRA.

  • New models for mortgage origination.

  • Legally enforceable Banking Code.

Key Issues
  • Responsible lending.

  • Mortgage broker remuneration.

  • Amendments to the Banking Code.

  • Extension of the BEAR regime.


Industry statistics confirm that post-Royal Commission, the non-major ADIs (including mutuals and neo-banks) have made inroads into the 4 majors' market share. 


Post-commission customer remediation costs will likely exert downward pressure on the 4 majors' bank profits for some time.

How we can help ADIs implement the RC's recommendations

  • Provide strategic advice to ADI Boards on their post-Hayne responsibilities – including those pertaining to BEAR and GCRA.

  • Deliver bespoke research on a specific Royal Commission-related area of interest.

  • Deliver bespoke training on the Royal Commission’s findings and recommendations.

  • Manage and execute, on the ADI’s behalf, an end-to-end project to address the Royal Commission’s recommendations.

  • Conduct due diligence on prospective solutions providers.

  • Conduct an independent review  of the ADI’s existing CGRA and BEAR arrangements.

  • Provide ADI Boards with updates on the changes to the Banking Code.

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