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Connexus : Issue 43
example, organisations that: • Offer a variety of banking and investment products. • Regularly update investors on their product’s ﬁnancial performance without providing corresponding information about their charitable operations. • Have websites that appear to be like the websites of commercial operators. • Compare their investment products directly with products issued by commercial fundraisers. “Recent high-proﬁle collapses of retail-funded shadow banks in Australia have demonstrated that some retail investors engage with shadow banks as though they were a real bank,” says ASIC. “A similar risk applies with respect to charitable investment fundraisers, particularly given the commercial scale at which some fundraisers operate and the degree to which some fundraisers actually appear to be like a bank,” ASIC says. Luke Lawler is the Customer Owned Banking Association senior manager, public a airs. Imposing quasi- prudential regulation on debenture issuers puts these vehicles into a regulatory twilight zone... Customer Owned Banking Association submission to APRA www.customerownedbanking.asn.au 21