ANZ acknowledged the proceedings and said it would consider ASIC’s claims, but could not comment further as the matter was now before the courts. “ANZ has co-operated with ASIC during its investigation and has established a customer remediation program as well as continuously improving its home loan processes and controls,” the bank said.

Introducer programs were heavily criticised during the banking royal commission when it was revealed NAB had had failed to manage personal relationships between bankers and introducers, and some loans were approved using falsified and unverified documentation. NAB was eventually fined $15 million for the scheme, which included using at least one gym owner to grow the bank’s mortgage book and paying $1 million in commissions.

NAB formally closed its introducer scheme in late 2019 after then-interim chief executive Phil Chronican earlier that year concluded that it was the “right thing to do.”

Royal commissioner Kenneth Hayne’s final report into the banks found the introducer schemes were “not incompatible with responsible lending obligations” but ultimately did not call for them to be banned. ANZ continues use its scheme that it brands as a simple way for sports clubs, schools and community organisations to make additional cash.

Individuals or organisations with an Australian Business Number can apply to be paid under the scheme, which involves commissions of around 0.3 per cent of the home loan once it is settled with ANZ.

Internal communications from Western Australian Bowls, a collective of more than 200 bowls clubs around the state, shows one organisation that had promoted the scheme as “an easy way to earn significant income for your club”.

“A typical $400,000 home loan will earn your club $1,200 - very good money for very little effort,” the 2018 memo claimed, obtained by this masthead. “ANZ staff members are very prepared to visit clubs and give a 10-minute presentation – perhaps at your AGM.”

Responding to questions from the federal government’s economics committee in 2019, ANZ claimed the accreditation process for the introducer scheme typically takes between two and four weeks, which includes police, bankruptcy and fraud checks.

Argo Investments senior investment officer Andy Forster said the introducer programs raise risks of breaching responsible lending laws and the banks should instead focus on investing more in technology to grow mortgage books.

“On the processing side, the banks seem to want to throw more people at, whereas they need to invest in the technology and get the technology right,” Mr Forster said. “But it’s hard when you have these legacy systems.”

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