Yes?And interest rates were corrected between June and September of 2017. MR DINELLI: Did you turn your mind to 912D again in this context?I wasn’t in the meeting when the compliance impact assessment discussion was Yes?Was raised. Do you know what they – what was determined?Yes, I do. So they determined it wasn’t significant. I see. So you can’t comment on whether or not they had regard to the number and frequency of similar past breaches?I don’t think we’ve had a similar breach of this nature. I do know they had regard to the time period that it persisted over, which was six months. The number of customers impacted, the dollar impact, which has been about $980,000. THE COMMISSIONER: I’m 980?980, yes, Commissioner. And number of customers?1860. MR DINELLI: That decision as to whether or not to inform ASIC was reconsidered about two months later, wasn’t it?Yes, it was. Were you part of that decision?No, I wasn’t. Is it common to reconsider whether or not – whether or not a disclosure should be made?Well, I think based on, you know, further information, I – I think that the team wanted to make sure that we were still comfortable that that was the right decision. But then the same conclusion was reached, wasn’t it?Yes, it was. And the customers have now been remediated in relation ?Yes. They have, yes. this issue, but it remains the case that ASIC hasn’t been notified of it?That’s right. Can I go to item 134. THE COMMISSIONER: Sorry, can I just understand who makes the decision report or not report to ASIC?Yes. At what level or what body ?Yes. within the bank makes that decision of report or no report?Yes. So that’s where the sort of key business stakeholders, sort of – you know, people at my sort of
Do you see that?I do. And it sets out then a summary of the – some of the requirements under the National Credit Act?Yes. Now, is it the case that if one goes down under the heading Methodology, there is a – an indication that the following classes are considered higher risk from responsible lending perspective? Higher value – high loan value ratios?Yes. And likewise, in terms of the sample selection methodology that’s to be used, immediately below that, there’s actually a focus on borrowers with an LVR of over 150 per cent. Do you see that?That’s correct. So is it the case that an LVR is a relevant consideration in the course of considering responsible lending obligations?So – and forgive me, but I may be misunderstanding the question, but – but these – these factors that you pointed to on this – on this document, this is what we use to identify cohorts of customers for whom there might be a higher risk of responsible lending issues. So – so typically, a customer who has borrowed a higher LVR might be a little more stressed in their financial circumstances more generally. So that would be a good place to go and have a look to explore whether we’ve done everything that we need to do. So – so it’s about – it – it actually describes a cohort of customers, rather than saying the LVR itself creates the responsible lending issue, if that makes sense. I see. But as I understand – as I understand Westpac’s policy, it’s willing to offer a customer loan for 80 per cent more than the market value of the product that’s being sold?In – in some circumstances, that’s correct. And just to be clear – and I dealt with some of this before lunch – but one reason why it might be – you use the example of a trade-in?Correct, and negative equity, yes. And negative equity. And that be one reason?Mmm. Another reason might be that it enables the payment of fees above and beyond the value of the car at the time of the purchase of the car?In combination, it’s With the car?Yes, always with the car. So certain fees are always payable, as I understand it, when you enter into a loan with Westpac. An establishment fee?Yes. Monthly administration fee. There might be some fees/charges on early termination. There’s an origination fee?Correct.