"By failing to have robust compliance and training processes in place, ANZ made it possible for third party intermediaries to misrepresent consumers' financial details in order to receive commissions on loans approved based on possibly misleading information," concluded Ms Court. ANZ admitted the contraventions and has agreed to conduct a review of its policies and procedures around its Introducer Program to ensure ongoing compliance with credit legislation. ANZ has also been ordered to pay ASIC's costs. In October 2020, National Australia Bank (NAB) paid a $15 million penalty for dealing with unlicenced home loan introducers.