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The fact that you are currently subject to the NCCP and ADIs aren't, isn't a conflict of interest in terms of the act.

Best option is avoid the conflict of interest by dumping CBA Second best option, if the perceived conflict can't be avoided, is full disclosure. Perhaps try something like this: "Ms Borrower, I recommend you take the CBA loan. It's not unsuitable to your needs though is more expensive...

If you feel you might be conflicted in recommendng CBA, either: (a) disclose said conflict to the client (b) remove said lender from your panel.