Product Disclosure & Sales Practice Policy¶


Code	`CON-004`
Domain	Customer & Conduct
Owner	Head of Product
Status	Draft
Applicability	Platform
Jurisdiction	NZ + AU
Business domain	BD04
Review date	2027-03-25

Regulations: CCCFA 2003 · NZ FMC Act · ASIC Act 2001 · NCC Act 2009 (NCCP)¶

Purpose¶

Govern product disclosure obligations, verbal and digital disclosure standards, and suitability assessment requirements for all banking products offered to customers. Ensures customers receive accurate, complete, and timely disclosure before accepting any product, and that products are not sold to customers for whom they are unsuitable.

Scope¶

All products and services offered to retail and small business customers across NZ and AU, including deposit accounts, payment products, credit facilities, and cross-border transfer services.

Policy statements¶

Every product accepted by a customer SHALL be preceded by complete disclosure of the product's key features, fees, interest rates, and material risks. Disclosure SHALL be made before acceptance and SHALL not be deferred to post-acceptance communications.

Where a Product Disclosure Statement (PDS) is required under applicable consumer credit or financial services legislation, the PDS SHALL be made available to the customer before product acceptance. Product acceptance SHALL be gated on customer receipt and acknowledgement of the PDS.

Digital disclosure SHALL be designed to maximise comprehension. Key fees and material risks SHALL be presented prominently and SHALL not be buried in general terms and conditions. The platform SHALL retain evidence that disclosure was presented and acknowledged for every product acceptance.

Verbal disclosure — where a product is explained or recommended by a staff member or agent — SHALL conform to a documented disclosure standard. Staff providing product explanations SHALL be trained and assessed on disclosure standards.

The platform SHALL not recommend or promote a product to a customer where the platform has reason to believe the product is unsuitable for that customer. Suitability assessment SHALL consider at minimum: the customer's stated purpose, financial position indicators available to the platform, and the product's known risk profile.

Fee changes and material product changes affecting existing customers SHALL be communicated with sufficient notice per the applicable customer code. Fee change communications SHALL clearly state the old and new amounts and the effective date.

All product disclosure events — including PDS delivery, fee acknowledgements, and material change notifications — SHALL be logged with a timestamp and channel reference for audit purposes.

Satisfying modules¶

Module	Name	Mode	Description
MOD-006	Rate change propagation	`ALERT`	Rate change event triggers customer notification obligation flag — feeds comms engine
MOD-027	Affordability calculator	`LOG`	Repayment amount, total interest payable, and total cost are captured on every affordability assessment row and returned in the response — the calling module (MOD-029) is responsible for invoking MOD-050 to deliver disclosure to the applicant before acceptance.
MOD-029	Pre-approval engine	`GATE`	POST /credit/applications/{id}/accept requires a disclosure_acknowledgement_id referencing a credit.disclosure_acknowledgements row recording the exact offer terms shown (content_hash covers rate, term, total interest, total cost) — returns 403 DISCLOSURE_NOT_ACKNOWLEDGED without it; no acceptance path bypasses this gate.
MOD-050	Disclosure enforcement module	`GATE`	Disclosure obligation met before every product acceptance — system enforces, no agent required
MOD-054	Call recording & transcript attachment	`LOG`	Product disclosures in calls captured and searchable — compliance QA can evidence verbal disclosure
MOD-108	Product offer engine	`LOG`	Every generated offer is logged with its terms, derivation basis, and lifecycle events (presented, accepted, rejected, expired) in an immutable offer audit trail.

MOD-109	Product deal engine	`LOG`	Every deal proposal, authorisation decision, and customer acceptance or rejection is logged immutably in the deal audit trail with the agent ID, authoriser ID, terms, and timestamp.

MOD-110	Fee engine	`LOG`	Every fee event (assessment, waiver, posting, reversal) is logged immutably with the fee type, amount, waiver reason if applicable, and applicable fee schedule version.
MOD-111	Term deposit maturity engine	`AUTO`	Pre-maturity notifications are sent automatically at 30, 14, and 7 days before maturity — no manual trigger required, no customer is missed.
MOD-112	Amortisation schedule engine	`AUTO`	Any event that changes the repayment schedule (rate change, extra repayment, hardship restructure) triggers an automatic updated schedule delivery to the customer within 24 hours.
MOD-113	Statement generation	`AUTO`	Account statements are generated and delivered automatically at the end of each statement period — no manual trigger; no customer is missed.
MOD-116	Mortgage servicing engine	`AUTO`	Rate election disclosure is enforced before the customer's rate election is accepted — customer cannot elect without confirming they have received the disclosure.
MOD-118	Member equity and share registry	`AUTO`	Members receive their annual member statement and dividend tax certificate automatically without requiring a manual request.
MOD-121	Construction loan drawdown engine	`AUTO`	The customer receives an updated amortisation schedule after each drawdown, reflecting the new principal balance and any change in the interest-only period remaining.
MOD-128	Credit bureau enquiry and CCR integration	`LOG`	Adverse bureau findings (score, adverse flags, bureau name) are captured on the enquiry record and returned structured to the caller; the calling decisioning module (MOD-029) is responsible for invoking MOD-050 to deliver disclosure to the applicant.
MOD-130	Notice account management	`AUTO`	Customer receives confirmation at notice lodgement, a reminder 7 days before the withdrawal date, and a notification on the day the withdrawal becomes available.
MOD-132	Loan restructure and variation workflow	`AUTO`	An updated disclosure showing the revised repayment schedule, new rate, and any break cost is automatically issued to the customer via MOD-050 before the variation is confirmed.
MOD-139	Financial hardship formal variation workflow	`AUTO`	The customer receives a formal variation agreement documenting the new terms, the duration of the variation, and the effect on their total interest payable before the variation is applied.
MOD-162	Loan facility & component manager	`AUTO`	Principal-weighted effective interest rate is recomputed and persisted to the facility record within 500 ms of every component event, making the current effective rate available for disclosure at all times.
MOD-167	Credit card facility engine	`GATE`	Minimum repayment disclosures and billing-cycle statements are gated on delivery confirmation before the next billing cycle opens.

Part of Customer & Conduct · Governance overview Compiled 2026-05-22 from source/entities/policies/CON-004.yaml