The Australian Securities and Investments Commission (ASIC) has issued a no-action letter reducing the internal dispute resolution (IDR) reporting frequency for certain small banks from every 6 months to annual reporting.
Small bank means an entity listed at Appendix A of the no-action letter.
Unless amended or revoked, the no-action letter applies in relation to the requirements to lodge IDR reports for the 6 month periods ending on 31 December 2025 and 31 December 2026.
ASIC does not intend to take action against a small bank for a contravention of:
- subparagraph 912A(1)(g)(ii) of the Corporations Act 2001; or
- paragraph 47(1)(ha) of the National Consumer Credit Protection Act 2009,
- to the extent they require the small bank to give ASIC the information (the IDR Report) specified in ASIC Corporations (Internal Dispute Resolution Data Reporting) Instrument 2022/205 in relation to a 6-month reporting period ending on 31 December 2025 or 31 December 2026.
ASIC’s no-action position is conditional on the small bank:
- preparing their next IDR Report (full-year IDR Report) to cover the 12-month period from 1 July 2025 to 30 June 2026 or 1 July 2026 to 30 June 2027 (as applicable); and
- submitting the full-year IDR Report to ASIC by 31 August 2026 or 31 August 2027 (as applicable).
The no-action letter does not prevent third parties from taking legal action in relation to that conduct.
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Author: David Jacobson
Principal, Bright Corporate Law
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About David Jacobson
The information contained in this article is not legal advice. It is not to be relied upon as a full statement of the law. You should seek professional advice for your specific needs and circumstances before acting or relying on any of the content.
