Fee & Pricing Transparency Policy¶


Code	`CON-005`
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 · ABA Banking Code · NZ Banking Code ¶

Purpose¶

Govern fee disclosure, FX spread transparency, fee waiver criteria, and the platform's no-surprise commitment to customers. Ensures that all fees and charges are disclosed before they are applied, that FX spread is treated as a disclosed cost rather than a hidden margin, and that the platform meets its obligations under consumer protection regulations in both NZ and AU.

Scope¶

All fees, charges, FX spreads, and pricing applied to customer accounts and transactions across all products and channels.

Policy statements¶

All fees and charges applicable to a customer's account or transaction SHALL be disclosed to the customer before the fee is applied. No fee SHALL be deducted from a customer account without prior disclosure and, where required, explicit acknowledgement.

FX spread on cross-border transactions SHALL be disclosed as a separate, quantified cost item before the transaction is executed. The spread SHALL NOT be embedded invisibly in the exchange rate without disclosure.

The platform SHALL provide customers with a real-time view of their current balance, available balance, and any pending fee deductions or holds before they initiate a transaction.

Fee waiver criteria SHALL be documented and applied consistently. Ad-hoc fee waivers outside the documented criteria SHALL require documented approval and SHALL be logged.

Fee schedule changes SHALL be communicated to affected customers within the regulatory notice period applicable in each jurisdiction before taking effect.

The platform SHALL not apply fees that are not listed in the current fee schedule. Any system-generated fee deduction that does not match the active fee schedule SHALL be treated as an error and SHALL trigger a reconciliation alert.

All fee disclosures, customer acknowledgements, and fee application events SHALL be recorded and linked to the relevant transaction or account event for audit purposes.

Satisfying modules¶

Module	Name	Mode	Description
MOD-003	Real-time balance engine	`AUTO`	Customer-visible balance is always accurate and current — no lag between transaction and display
MOD-005	Daily accrual calculator	`AUTO`	Interest earned displayed to customer reflects actual accrual — no rounding manipulation
MOD-006	Rate change propagation	`AUTO`	Rate change applied to all affected accounts on correct effective date — no manual per-account update
MOD-021	Payment limit & velocity controller	`AUTO`	Customer-set limits honoured immediately — no delay between setting and enforcement
MOD-025	FX rate lock & conversion	`GATE`	Spread disclosed to customer before confirmation — system enforces pre-disclosure not post-disclosure
MOD-041	Categorisation & merchant enrichment model	`AUTO`	Transaction descriptions and categories are accurate and meaningful — not raw acquirer strings
MOD-050	Disclosure enforcement module	`GATE`	Fee disclosure shown before any fee-generating action — no surprise fees
MOD-051	Financial automation rules engine	`LOG`	Rule execution logged and visible to customer — full transparency of automated actions
MOD-069	Customer app shell	`AUTO`	Displays fee disclosures and regulatory notices in the correct position within user flows — disclosure gates are enforced by the shell before navigation proceeds.
MOD-070	Transaction history & search	`AUTO`	Customers can view a complete, accurate transaction history with fee and FX detail for every entry — no charges are hidden or obscured.
MOD-071	Payment initiation	`AUTO`	Displays the applicable FX rate, markup, and fee clearly on the confirmation screen before the customer commits to a payment.
MOD-077	Account dashboard & insight feed	`AUTO`	Displays account balances, accrued interest, and fee information accurately and in real time — the dashboard is the customer's primary source of financial truth.
MOD-110	Fee engine	`GATE`	Fee posting is blocked if the required advance notice period has not elapsed since the fee schedule was last changed — enforcing the notification-before-deduction obligation.
MOD-111	Term deposit maturity engine	`GATE`	Early withdrawal is blocked until the break cost is calculated, disclosed to the customer, and explicitly accepted — no funds are released until acceptance is recorded.
MOD-112	Amortisation schedule engine	`CALC`	Total interest payable and effective annual rate are computed from the schedule and displayed on the product dashboard at all times.
MOD-113	Statement generation	`AUTO`	Statements include all fees, interest, and charges for the period with clear disclosure of basis and amounts.
MOD-116	Mortgage servicing engine	`GATE`	Break cost calculation is disclosed to the customer before any early repayment of a fixed rate loan is processed.
MOD-117	Overdraft management engine	`GATE`	The current overdraft limit, interest rate, and monthly facility fee are disclosed to the customer before any limit is activated.
MOD-119	BPAY payment integration	`AUTO`	BPAY biller name and reference are displayed in transaction history with full detail — no generic merchant string.
MOD-120	PayID and Osko integration	`AUTO`	The resolved account holder name is displayed to the customer before confirming an Osko payment — confirmation of payee name is mandatory.
MOD-121	Construction loan drawdown engine	`CALC`	Interest accrues only on the drawn balance — not the total approved facility — ensuring the customer is not charged interest on undrawn funds.
MOD-123	ATM network integration	`AUTO`	Surcharge-free network membership details are disclosed to the customer in the app so they know which ATMs can be used without fees.
MOD-127	Product configuration panel	`GATE`	Any rate or fee change that is unfavourable to customers is blocked from taking effect until MOD-063 confirms that all affected customers have been notified with the required advance notice period.
MOD-130	Notice account management	`GATE`	Early withdrawal penalty is calculated and disclosed to the customer before any early withdrawal is processed — the penalty amount cannot be bypassed.
MOD-132	Loan restructure and variation workflow	`GATE`	Break cost disclosure must be acknowledged by the customer before any fixed-to-variable conversion or early repayment variation is processed — the variation is held until acknowledgement is recorded.
MOD-135	Batch payment and payroll file processing	`AUTO`	Customers uploading a batch must confirm the total amount and payment count before submission — no silent batch processing.
MOD-136	BPAY biller registration and inbound BPAY	`AUTO`	Biller is notified of each inbound BPAY receipt within 60 seconds via MOD-063 — timely disclosure of payment received (j-1 ruling; CON-001 is a stretch fit for this mechanism).
MOD-141	Intra-bank transfer engine	`AUTO`	The customer is shown both the debit and credit side of the transfer for confirmation before execution, making the immediate book-transfer nature transparent.
MOD-142	Deposit guarantee scheme disclosure	`GATE`	DCS (NZ) or FCS (AU) disclosure must be delivered and acknowledged by the customer at account opening before the account activates; disclosure is repeated in account statements and on the account detail screen.
MOD-163	Break-cost calculator	`GATE`	The binding break-cost calculation is delivered to the customer via MOD-050 for acknowledgement before any fixed-rate component early termination or pre-maturity rollover is processed; the component status handler verifies the acknowledgement record ID before proceeding; no code path bypasses this gate.
MOD-164	Facility component self-service	`GATE`	Prepayment and rollover flows in the self-service UI route through MOD-050 for binding break-cost acknowledgement before any fixed-rate component change is submitted — no UI path completes a fixed-rate component change without a confirmed acknowledgement record.

Part of Customer & Conduct · Governance overview Compiled 2026-05-22 from source/entities/policies/CON-005.yaml