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That's sort of my point re the banks. They know it will cost a lot to identify the genuine cases worthy of remediation. In many cases, the file won't even show whether the service was delivered or not. Lack of documented evidence in the file proves nothing more than a lack of documented evidence in the file. It is not proof of lack of service. "Guilty until proven innocent" might be ASIC's philosophy, but it's not the law.

The banks know that if they investigated properly, only about 20-30% of their "remediation" cases would be genuine lack of service. But they won't know which 20-30%, without a costly investigation. So they're prepared to pay out much more than they need to in order to save some investigative cost, and at the same time get a PR dividend thanks to their "contrite and caring" approach.

IOOF doesn't have a valuable brand to protect, and doesn't have lots of cash to blow on a PR stunt to protect it. Hence their more laser like approach to remediation.