Defined Terms and Documents

Financial System Inquiry website

• Discussion Paper - Released November 1996

• Final Report - Released March 1997

The Financial System Inquiry otherwise known as the Wallis inquiry presented its report to the Treasurer in March 1997

The Treasurer announced on 30 May 1996 the establishment of an Inquiry into the Australian financial system, to report to him by 31 March 1997.

The Inquiry is directed to provide a stocktake of the results arising from the financial deregulation of the Australian financial system since the early 1980s. The forces driving further change will be analysed, in particular, technological development. The Inquiry will make recommendations on the nature of the regulatory arrangements that will best ensure an efficient, responsive, competitive and flexible financial system to underpin stronger economic performance, consistent with financial stability, prudence, integrity and fairness.

The Inquiry is chaired by Australian businessman, Mr Stan Wallis and will be supported by a full time secretariat. The Secretary will be Mr Greg Smith who has been seconded from the Treasury. The secretariat will be responsible exclusively to the Inquiry and will include staff from the private sector and staff seconded from other agencies.

The Inquiry may be contacted at:

The Financial System Inquiry Secretariat
C-/ Treasury Building
Parkes Place
PARKES ACT 2600
Australia

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Chapter 3  Westpac publication - 1996

Instead an approach was adopted where banks and other financial institutions had much greater freedom to respond to competitive market signals and customer requirements, subject to meeting minimum prudential standards designed to protect depositors and maintain the stability of the financial system.

The success or otherwise of past deregulation should be gauged against this Inquiry’s objectives of having an efficient and competitive financial system, providing consumer choice, and maintaining the overall stability and integrity of the system. Also relevant is the Inquiry’s concern with fairness, or the equitable treatment of the various users of the financial system. Consequently, the focus of this discussion is restricted to these aspects of the impact of deregulation on the Australian financial system.

According to all the above criteria, deregulation has been successful:

1 The focus of this submission is on the banking sector. In addition, this submission does not attempt to gauge the broader effects of deregulation on growth and the economy at large.

2 For a full account of the historical background to deregulation and the deregulatory measures which were implemented during the 1980s see A Pocket full of Change, Banking and Deregulation, House of Representatives Standing Committee on Finance and Public Administration, November 1991, chapter 2; and Fast Money 3, the Financial Markets in Australia , Edna Carew page 1 - 30.

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Prior to deregulation, Governments sought to use the banking system as a means of achieving monetary policy objectives. Some of the restraints that were imposed on banks included:

A direct consequence of these restraints was the rationing by banks of funds available for lending. Lending rate controls made banks a cheaper source of funds than finance companies and building societies, which only increased the potential bank borrower demand, further exacerbating the loan demand/supply imbalance. In this environment:

purposes. Interest rate ceilings on bank deposits meant that customers wanting a better

yield had to seek out higher rates from more risky institutions outside the banking

system. However, customers who wanted greater security (particularly low and middle

income earners and groups such as pensioners) or had cheque accounts had no option

but to keep their funds in no interest or low interest bank deposits and hence, indirectly,

subsidised those fortunate enough to be borrowers; and

With deregulation, rationing of funds by banks ended and the dismantling of cross

subsidisation between bank customers began. Both led to greater efficiency in the

workings of the financial system and more equitable treatment of all bank customers.

3 There were a variety of prescriptive limits on interest rates that banks could apply to loans, including

ceilings on rates charged on small overdrafts, which resulted in the rationing of overdrafts to the most

credit-worthy business customers. Interest rate ceilings on new owner-occupied housing loans of less than

$100,000 were the last of the lending rate controls and were maintained until April 1986.

4 For example, prior to August 1984, there was a rule applying to trading bank deposits which disallowed

banks from paying interest on deposits taken for less than 14 days or to pay interest on cheque accounts.

33

With the removal of lending and interest rate controls, bank customers began to receive

competitive market-related rates on their deposits and were offered a greater variety of

deposit products. As interest was paid on cheque accounts, and bank depositors became

more interest rate sensitive, a shift occurred in balances out of accounts which traditionally

had paid a zero or low interest rate to higher yielding accounts, as shown in Figure 3.1.

As a result, the proportion of funds in current accounts not bearing interest has declined

significantly, from 20.5% in 1980 to 5.4% in 1995. Meanwhile the funds in high interest

fixed term deposits and CDs have increased from 31.5% to 57.2% of total deposits over

the same period.

Note: Low interest accounts are non-interest bearing accounts and transaction and

passbook accounts.

Source: RBA Occasional paper No. 8.

With the removal of lending controls, banks were in a position to meet a greater share of

the borrowing needs of ordinary Australians. Customers in turn benefited from improved

access and many also benefited from lower cost borrowing, than had been generally

available from non-bank sources pre-deregulation. Not all borrowers, however, paid lower

interest. The unwinding of the cross-subsidy to borrowers from those depositors who,

prior to deregulation, were receiving no or low interest rates and the removal of interest

rate ceilings, saw those borrowers fortunate enough to get controlled rate bank loans prior

to deregulation begin to pay market rates. These changes resulted in a significant

improvement in the equity of access to bank financing.

Banks’ share of lending relative to lending by other financial intermediaries has risen from

58% in 1980 to 77% in 1995. However, it should be noted that the increased share also

reflected the conversion of building societies to banks and the absorption of money

market corporations and finance companies by some banks. Without these conversions

and absorptions, banks’ share of lending would have remained unchanged at 58%.

0%

20%

40%

60%

80%

100%

1980 1981 1982 1983 1984 1985 1986 1987 1988 1989 1990 1991 1992 1993 1994 1995

Non Interest Bearing Accounts Transaction and Passbook Accounts

Interest Bearing Current Accounts Fixed Deposits and CDs

34

Following deregulation and the lifting of controls on lending, banks turned to borrowing in

This development, in association with the payment of market-related interest rates on

deposit accounts resulted in the overall cost of funds increasing for banks. Banks’

shrinking reliance on low interest deposits for lending purposes, from 57% to 14% of

liabilities between 1980 and 1995, is clearly illustrated in Figure 3.2.

Source: The Evolving Structure of the Australian Financial System, M. Edey & B. Gray,

1996, forthcoming and RBA Occasional paper No.8.

The diminishing level of low interest deposits has meant that the level of crosssubsidisation

between depositors and borrowers has greatly decreased, although the

unravelling of cross-subsidies, particularly as they still apply between transaction account

holders and borrowers, still has some way to go.

The deregulatory measures implemented in the early to mid-1980s, the increased

competition in both the lending and deposit markets (between banks and other financial

institutions), and banks’ greater reliance on the more expensive professional money

Between 1980 and 1995, domestic net interest spreads reduced from 5.0% to 3.9%, as

can be seen in Figure 3.3.

5 Professional market borrowings (bill acceptances, other Australian liabilities and foreign currency

liabilities) have risen from 11.4% of funding in 1980 to 29.1% in 1995.

6 The net interest spread is the average interest rate received less the average interest rate paid.

1980 1981 1982 1983 1984 1985 1986 1987 1988 1989 1990 1991 1992 1993 1994 1995

Investment and Transaction Accounts

Passbook Accounts

Current Deposits Not Bearing Interest

16 16 17 18

49

22

33

30

41

48

18

30

45

55

57

14

35

Source: RBA, Annual Report 1996.

This 1.1% reduction cannot easily be quantitatively attributed to its various causal factors.

However, it is clear that the Australian economy is more efficient by having the net cost of

intermediation, as measured by the interest spread reduced by this amount.

In simple terms, the benefit today to bank savers and borrowers of a 1.1% reduction in

interest spread would be equivalent to more than $3 billion. In anyone’s language, this is a very large amount.

The large bank mergers in 1981 between, on the one hand, the Commercial Bank of

Australia and the Bank of New South Wales, and, on the other hand, between the

National Bank of Australasia and the Commercial Banking Company of Sydney, provided

the initial impetus for the resource rationalisation that has taken place since the early

1980s. In addition, the decline in margins, the poor experience with loan losses in the

early 1990s (see Section 3.3) and the more recent disaggregation of the banking market

that has been taking place (see Chapter 4), have all acted as inducements to bank

management to reduce operating costs and increase efficiency.

In the period since deregulation, the major banks have reduced costs in numerous ways.

Between 1983 and 1994, they closed 15% of their branches, particularly in areas where

revenues were insufficient to justify their retention. The most significant reductions have

occurred between 1990 and 1994, when 12% of branches were closed. Branch closures are still taking place.

Staff numbers in the retail operations of banks have reduced by almost 5% between 1983

and 1994, despite a 25% increase in the volume of retail transactions and a significantly

broader product and service base. Between 1983 and 1990, retail banking employment

rose by 37%, reflecting the entry of new banks and substantially increased business

levels. The main efficiency gains have thus come in the 1990s, with a decline in

employment levels of 30% between 1990 and 1994.

5.0 4.9

4.5 4.5

4.8

4.3 4.1 4.1

5.0

4.4

3.9 3.8 3.8 3.9 4.0 3.9

0.0

0.5

1.0

1.5

2.0

2.5

3.0

3.5

4.0

4.5

5.0

1980 1981 1982 1983 1984 1985 1986 1987 1988 1989 1990 1991 1992 1993 1994 1995

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These efficiency gains are associated with large-scale reorganisations by banks in the

way their personnel provide banking services to personal and business customers. They

have outsourced activities that can be provided more cheaply and efficiently by external

of scale which can operate in many sectors of the financial services market, particularly

through the centralisation of certain processing functions and the judicious use of new

These initiatives have resulted in measurable increases in efficiency. The proportion of

domestic non-interest expenses make up of the net income earned by banks has declined

from approximately 73% to 61% between 1982 and 1995 (see Figure 3.4).

Source: Annual reports of major banks.

Another measure of efficiency improvement is that of operating costs as a percentage of

total average assets. Between 1980 and 1995, the banking industry saw an improvement

from 4.2% to 2.9% in this ratio as outlined in Figure 3.5.

can be shaved off this ratio is equal to about $456 million in cost savings a year, relative

to that level of assets.

7 For example cash distribution, voucher storage and computer maintenance.

8 The new telephone banking services set up by banks are an example of using technology and

centralisation to be able to have a smaller number of specialists deal with a large number of customer

inquiries.

9 May 1996

72.9 72.5

69.0 68.3 68.9 65.8 63.8 61.2 63.2 63.7

66.9 63.9 62.9 61.4

0

10

20

30

40

50

60

70

80

1982 1983 1984 1985 1986 1987 1988 1989 1990 1991 1992 1993 1994 1995

37

Source: Annual reports of major banks.

Attributing the above significant efficiency improvements across the range of changes that

occurred throughout the 1980s is not possible. For example, rapid asset growth,

particularly in overseas markets where corporate lending dominated activities and there

was no requirement to build extensive branch networks, also contributed to the

improvement in the expense/asset ratio.

What is evident, however, is that around 70% of the efficiency improvements occurred

between 1981 and 1986. This period coincided with the two major mergers that created

Westpac and the National Australia Bank. The resulting rationalisation benefits

contributed to the above efficiency gains. This is evident from the operational efficiency

measures for the merged banks. The reductions of 33% in the expense to asset ratio for

both Westpac and the NAB between 1982 and 1986, compared to reductions of 14% for

the Commonwealth and 9% for the ANZ, suggest that the mergers contributed to the

efficiency improvements through this period, to the benefit of users.

Although significant efficiency gains have been achieved since deregulation, these gains

are not yet enough. Australian banks still need to become more efficient if they are to be

globally competitive. The 1995 study undertaken by the McKinsey Global Institute

(referred to in Chapter 2), showed Australian retail banking productivity as up to 40%

behind the levels achieved in the USA (see Figure 3.6).

4.2 4.1

4.4

3.8 3.7 3.5 3.3 3.3 3.4

3.1 3.1 3.2

3.5

3.2 3.0 2.9

1980 1981 1982 1983 1984 1985 1986 1987 1988 1989 1990 1991 1992 1993 1994 1995

38

(Index US = 100*)

Note: Composite index of productivity for payments, deposits and credit services,

weighted by functional labour input; US, Swedish and German data are for

1992, Australian for 1994.

Source: Growth Platforms for a Competitive Australia, McKinsey and Company Australia

and the McKinsey Global Institute, page 102.

As the McKinsey report says: “Australian activity levels per capita are well below those in

the United States, but are similar to European levels. Transactions per capita are around

47 per cent of the US level, while estimated loan accounts outstanding are around 60 per

cent of the US level. These relatively low per capita activity numbers, when combined with

Australia’s high number of branches per capita, result in low activity per branch. .... Our

research suggests that the major cause of lower labour productivity in Australian retail

The report notes that “Australia has more branches per million population than the United

population densities outside major cities and regional centres, and nature of competition

before deregulation, when the convenient location of branches was one of the few

competitive levers available to banks. Although industry participants have long recognised

the benefits of industry consolidation and the value of alternative distribution channels,

they have been deterred from pursuing large scale closures because of historical market

and regulatory factors”, such as Trade Practices Act and competition policy restrictions on

11 A 1996 Baring McIntosh survey which included only banks showed that Australia had 372 bank branches

per million inhabitants compared to 282 in Canada, which is also relatively sparsely populated, and 229 in the UK.

Institute, pages 103 - 106.

60

72

80

100

0 20 40 60 80 100

Australia

Germany

Sweden

US

39

(Branches/million population, 1993)

Note: 1994 Business Establishment Survey. All branches of banks, building societies

and credit unions included.

Source: Growth Platforms for a Competitive Australia, McKinsey and Company

Australia and the McKinsey Global Institute, page 105.

To be able to compete in an increasingly global marketplace and to continue to bring real

benefits to customers, both borrowers and savers, domestic banks need to reduce their

expenses further, and in particular, the number of branches. Consumers are already

benefiting from new ways of transacting business other than by going into branches.

However, they are not prepared to pay the costs of operating both the old and new

technologies. For increased efficiency, the number of branches in the Australian banking

system needs to be reduced, both through individual bank efforts and through merger

rationalisation.

McKinsey have estimated that the benefits to the Australian economy of achieving US

retail productivity levels could be between $1.8 and $3.6 billion (see Figure 3.8).

900

670

580

509

445

380

325

325

310

305

0 100 200 300 400 500 600 700 800 900

Spain

Germany

Switzerland

Australia

France

Italy

Sweden

Netherlands

UK

US

40

* Assumes that average non-interest expense for a branch is $1.6 million for major banks

and $0.8 million for all other institutions.

** Upper bound assumes branch closures spread proportionately across major banks and

others. 50% expansion in employees per branch assumed to be required in remaining

branches. Lower bound of saving assumes that productivity improvements takes form of

employment reduction without savings in premises cost. Employment accounts for

around 50% of non-interest expense.

Source: Growth Platforms for a Competitive Australia, McKinsey and Company Australia

and the McKinsey Global Institute, page 102.

Increased competition in the financial marketplace has come about as a result of the

dismantling of some of the previously described controls, the entry of new competitors as

licensed banks and heightened competition among existing players. This has resulted in

significant benefits for consumers and businesses through greater convenience and

choice.

With the exception of building societies and finance companies that have converted or

been absorbed into banks, the choice of institution with which consumers and businesses

have been able to conduct their financial services transactions has significantly increased,

as demonstrated in Table 3.1.

Total Non-Interest

Expense Retail

Banking Industry*

Savings from

Achieving US

Productivity**

Potential Non-

Interest Expense

11.0 1.8 - 3.6

7.4 - 9.2

41

Banks 19 43

Building Societies & Credit Unions 765 321

Finance Companies 117 103

Merchant Banks 59 83

Mortgage Originators 0 26

Funds Managers 35 93

Source: Council for Financial Supervisors, Annual Report 1995, CANNEX, Campbell

Inquiry, Interim Report, ASSIRT.

The share of assets currently held by each of these different category of institution is

shown in Figure 3.9. This illustrates the importance of the roles played by banks and life

offices and superannuation funds in the financial system.

100% = $956 bn

Note: Other funds managers include cash management trusts, common funds, friendly

societies and public unit trusts. Other financial corporations include authorised

money market dealers, pastoral finance companies, general financiers, general

insurance offices, other FCA companies, securitisation vehicles and cooperative

housing societies.

Source: RBA Bulletin, April 1996.

Building Societies &

Credit Unions

Finance Companies 3%

3%

Merchant Banks

5%

Life Offices and

Superannuation

Funds

26%

Other Fund

Managers

6%

Other Financial

Corporations

10%

Banks

46%

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There has been a dramatic increase over the past two decades in the ease with which

banking business can be transacted, brought about both as a result of increased

competition in the deregulated market and as a result of the technological innovations that

have been introduced.

No longer do bank customers physically need to visit a branch between 10.00 am and

3.00 p.m. (or 5.00 p.m. on Fridays) in order to deposit or withdraw cash, pay off credit

cards or transfer amounts between accounts. Not only are the branches open longer

hours, but all of these functions can be carried out at the now ubiquitous automatic teller

machine, located in shopping malls, in airport terminals and outside most banks. Goods

can be paid for and funds often can be withdrawn at more than 100,000 EFTPOS

terminals, even more conveniently located at service stations and in supermarkets and

other stores. Banks have also begun opening compact banking kiosks at which a broad

range of transactions can be carried out in supermarkets or shopping malls during

extended hours, seven days a week.

Increased consumer convenience has also come about through innovations that allow

customers to pay bills over the phone with a credit card and to carry out a variety of

banking transactions any time of the day using the new phone banking services. Home

loans can be initiated over the phone or with a mobile banker that visits the customer’s residence.

The number of points at which customers can carry out transactions has dramatically

increased (see Table 3.2) as have the number of hours per week customers can have

banking facilities readily available (see Table 3.3).

Bank Branches 5,859 6,655

ATMs 25 7,178

EFTPOS - 107,702

Telephone - 11,600,000 *

Internet - up to 800,000 **

* This is the number of telephone and mobile phone connections. There are

currently 13 banks with extensive phone banking facilities.

** Estimated number of Internet users in mid 1996. Usage growing rapidly, with an

estimated 1.9 million households having a PC and 950,000 having a modem in

1995/1996. Most banks have Internet ‘home pages’ with Advance bank being

the only one yet to allow value transactions on the Internet.

Source: RBA Bulletins, Annual Reports, ABA Submission to Campbell Inquiry, Australia

Payments System Council Annual Report 1994/95, Telstra, Paul Budde

Communications and www.consult.

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Bank Branches 27 33.5-42.5

ATMs 112 168

EFTPOS - 168

Telephone - 168

Internet - 168

Source: Westpac

Businesses are also far better served now than they were 15 years ago, with increasing

penetration of desk-banking from the large corporate level to small businesses, allowing

customers direct electronic access (via PC and modem) to their bank accounts.

Customers review their statements, organise payments to suppliers, receive funds from

customers and transfer funds, all via electronic means in their own offices. Banks,

particularly the large ones, have also established specialist small business service units.

Management information systems are provided to help small business owners run their

businesses better and in many cases mobile managers visit small business customers at

their workplaces, taking banking services directly to them.

Product and supplier choice has increased enormously for consumers of bank products.

For example, before deregulation, if a customer was eligible for a bank home loan, there

were 26 different types of mortgages available. However all were of a credit foncier type

with equal monthly payments made up of an interest and principal component. Today

there are over 1800 different mortgage products available. Home loan customers can

choose between fixed rate and variable rate loans or a combination of both, between

loans which afford customers considerable flexibility in their repayments and may even

have credit card and savings account options attached to them, to less flexible, lower cost

loans. And the loans are available from banks, building societies, superannuation funds,

life companies and mortgage originators.

Cheque accounts provide another example of the enormous proliferation of choice.

Before deregulation, the 10 different cheque accounts offered charged a minimum fee as

well as a “per cheque” fee and they paid no interest. Today there are 533 cheque account

options available, most of which pay interest on credit balances. Many have no fees

except government changes.

Similarly credit and debit card choices are now numerous and include value added

benefits and services via the associated loyalty programs that come with many cards.

Australians now hold over 7 million credit cards compared to 3 million in 1980 and they

can use them at over 350,000 different merchants.

Savings accounts and transaction accounts (all 1,700 different product types compared to

almost 700 in 1980) can be chosen by customers on the basis of their specific needs and

transaction patterns. All manner of financial products and services now can be tailored

very specifically to suit an individual customer’s requirements.

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The enormous increase in diversity of choice, both of supplier and product, has come

about as a result of a more competitive financial services market. The amount of choice

will increase further as technology enables providers to match their products and services

more closely to individual customer requirements. In addition, the level of the competition

in the market cannot be gauged by reference to one particular type of institution and the

number of competitors of that type in the market. Different categories of institutions are

now marketing the same product types.

From the mid 1980s, banks were free to set their own interest rates on all lending, and

were relatively unrestrained in their ability to grow their balance sheets and increase

market share. Like their international counterparts, Australian banks pursued growth

strategies, in part reflecting the inflationary and high growth economic environment, driven

by (inter alia) overly expansionary monetary policy. The combination of conditions resulted

in excessive lending to business (to the property sector and to offshore borrowers in

particular) and, subsequently, in large loan losses.

These loan losses did not flow from deregulation itself. They flowed from the combined

effect of monetary policy that inadequately adjusted to the impacts of deregulation; an

economic environment in which escalating asset values came to be considered the norm;

and inadequate credit and operations risk management in the banks. Banks were

evolving from the managerially simple world of regulation to the managerially complex

world of deregulation. Inadequate risk management was a common institutional failing in a

rapidly deregulating environment across the world.

Consequently, in excess of $16 billion of loan losses were written off by the major banks

and other financial institutions over the period from 1990 to 1993. Two State banks failed,

resulting in additional losses of over $5 billion, as well as a number of non-bank financial

intermediaries. Collapses sometimes lead to a loss of confidence in other institutions. For

example, the Farrow / Pyramid Building Society situation was a factor in an unjustified

depositor run on the Bank of Melbourne. While the Federal Government did not pay

directly for any of the collapses, there were tax impacts in connection with the State bank

failures. State Government budgets and the taxpayers of those states bore the direct

costs.

Despite all of this, the integrity of the financial sector has been maintained and, it could be

said, subsequently even strengthened as a result of the adversity. No depositor lost

money, and the stability of the payments system was never in question.

Regulators have successfully engineered bank reconstructions or judicious

amalgamations of strong and weak banks and, together with action by governments, both

in Australia and overseas, have maintained depositor confidence, despite the enormous

potential impact on the financial system.

In all instances, the reasons for the banking and payments systems having emerged intact

reside in the prudential oversight of banks (including interventionist support when

absolutely required), and the ability of banks from a systemic perspective to withstand

such shocks because of their strong balance sheet and liquidity management.

45

The business of banking is about risk management and containment. The ultimate risk is

always that the payments system will not operate with complete integrity. In the period

since deregulation, the system has withstood some rigorous tests.

A less obvious, but equally positive outcome has been improvement in credit assessment

and control and general risk management procedures that have been implemented in all

banks in response to the experience.

Explicit controls on banks to assist the Government achieve its policy objectives have, for

the most part, disappeared. In their place, however, a system of prudential supervision

and regulation has emerged for each of the main financial participant groupings (banks,

building societies, credit unions and insurance companies), and a growing body of

consumer protection legislation. Competition policy and prices surveillance have also

emerged as important dimensions of the overall financial system regulatory framework.

The regulation listed in Table 3.4, has all been introduced or strengthened in the last

decade. Legislation and regulation are increasingly being put in place by Federal and

State Government agencies that lack national coherence and deal with problems, or

perceived problems, in isolation. These are discussed in later chapters of this

Submission.

Over the past decade, the Reserve Bank has regularly released new prudential

statements for the banking sector. Often issues are dealt with in a prescriptive manner

rather than through a more outcomes-oriented approach. The risk is that the prescriptive

approach can result in “average” regulation, which does not differentiate between the

various participants as regards the calibre of their boards and managements, the strength

of their balance sheets and their risk management systems. The challenge is to rely more

on the managements and boards of banks to run their businesses within the broader

prudential guidelines set by the Reserve Bank and its international counterparts.

The Reserve Bank, however, has recently signalled a modification to its approach and

appears to be moving in the direction of placing more reliance on bank management to

endorse compliance with pre-approved internal risk management systems, and with

external auditors playing a more active audit role.

Deregulation has largely been very successful, bringing considerable efficiency benefits to

the Australian economy, greatly improving the range and pricing of financial services to

consumers, and increasing the competitiveness of the financial services markets while

maintaining system stability.

However, there is room for still greater efficiency and flexibility. The financial system would

be enhanced by a more efficient regulatory framework; that is more nationally consistent

in its application across various participant groups; that has the capacity to vary the extent

of supervision and regulatory oversight according to the level of risk; and that limits the

build-up of increasing layers of regulation.

46

operational liquidity for credit unions and building societies)

and report on the compliance of banks, credit unions and building

societies with their respective Codes

and pressure on banks to provide “affordable access” to their accounts.

business and to lend less for housing

products on their own account

industry funds

two major life offices

accounts and reporting requirements for suspect transactions

Source: How Does Regulation Affect the Future Role and Competitiveness of Banks?

Michael Waterhouse, Australian Banker, page 51, April 1996.