Question
UNO Bank (UNO), an ADI and ACL holder, operates through 700 branches across Australia. Your Home is a home loan product issued and promoted by
UNO Bank (UNO), an ADI and ACL holder, operates through 700 branches across Australia. "Your Home" is a home loan product issued and promoted by UNO Bank. UNO Bank runs an aggressive marketing campaign to distribute "Your Home" through its retail branch network. Every "Your Home" customer is offered $10k cashback as part of the promotion. The distribution process developed and implemented by UNO involved the following steps:
- Firstly, the branch staff member asks the prospective 'Your Home' customer to fill in a questionnaire of 25 questions (called '1-25 review') on the financial situation, needs, and circumstances of the customer. At the end of the review, customers are provided with a choice to submit the review itself as a loan application.
- Secondly, the branch staff member provides a 'credit guide' that includes the credit quote, financial table, disclosure documents, a pre-approved loan offer, and an information statement enumerating the documents to be submitted for processing the loan application to the customer.
- Thirdly, the retail customers who have submitted the required documents mentioned in the information statement are provided with a 'fast-track' application channel to approve the loan within 24-48 hours.
Question: Employed in the legal division of UNO and you are asked to review if the sale and distribution of "Your Home"breachany provisions of theNCCPA.
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