The banking royal commission has released a report by the corporate regulator that the National Australia Bank tried to keep secret.

Key points: Numerous NAB companies including MLC and Nulis are named in the confidential report

Numerous NAB companies including MLC and Nulis are named in the confidential report ASIC said it suspects NAB and its entities have committed numerous 'serious and systemic' contraventions and charged fees to deceased estates

ASIC said it suspects NAB and its entities have committed numerous 'serious and systemic' contraventions and charged fees to deceased estates Some of the suspected breaches are punishable by the cancellation or suspension of a financial services licence

The confidential ASIC report from October 2017 slams the NAB's overcharging of customers in what has become known as the fees-for-no-service scandal.

Numerous NAB companies are named in the report, including superannuation firm MLC, and superannuation trustee Nulis.

The report outlines suspected breaches of the Corporations Act and the ASIC Act by the bank.

Earlier this week the commission heard NAB admitted breaking the corporate law 84 times between 2014 and 2017 because it failed to inform the corporate regulator quickly enough about the fees-for-no-service scandal.

Under the Corporations Act the bank should have told ASIC about breaches within 10 days.

NAB is paying back nearly $90 million to customers who were wrongly charged.

ASIC said it suspects that NAB and its related entities have committed numerous contraventions of several sections of the Corporations Act.

"The suspected contraventions ... are serious and systemic," ASIC said.

"As is evident from extracts from the breach reports submitted by NAB and the related NAB entities reproduced within this paper, those entities have, by their own admission, fallen below the standard expected of a responsible Australian financial services licensee.

"In short, they have failed to do all things necessary to ensure that the financial services provided by them are done so efficiently, honestly and fairly."

The report carries a blunt warning that NAB's failings "demand a significant regulatory response".

"Moreover, the failures have occurred across a number of NAB group entities, meaning this was not an isolated problem, but a systemic failure of fundamental controls within the NAB group."

Suspected breaches punishable by cancellation of licence

ASIC said in the report the law breaches concerned NAB charging fees for services not provided and various breakdowns in fundamental systems and controls.

The bank also charged fees to deceased estates.

Some of the suspected breaches include "numerous contraventions" of Section 912A of the Corporations Act which can be punished by the cancellation or suspension of a financial services licence.

ASIC also said NAB may have committed criminal offences by breaching the ASIC Act concerning misleading and deceptive behaviour.

The regulator said NAB's correspondence with superannuation fund members about plan service fees may have been misleading because the bank failed to tell members they could opt out of the fee.

NAB admitted to ASIC in the report there were problems with the monitoring and supervision of financial licensees.

"Failure to exercise the requisite degree of care and diligence could be described as evidence of an inadequate compliance arrangement," NAB told ASIC.

NAB also admitted its controls over the charging of an adviser service fee had not been effective and there was "a breakdown in the administration process at the licensee level".

The report said NAB's failure to provide ongoing services while continuing to charge fees was "widespread and affected a large number of clients over a period of many years".

The ASIC report said it appears that senior management at NAB was aware of the problem as early as 2010 with complaints made by customers that they had paid adviser service fees but got no ongoing service.

About 40 complaints were made to NAB about the problem from January 2012 to February 2015 with those customers repaid more than $155,000.

But NAB Financial Planning recorded complaints received as early as 2009.

Some of the complaints from customers included: "Client alleges he has paid adviser fees for 4 years but has not received any service in that time" and "Client alleges he has received no ongoing service since 2008".

Another customer complained in early 2015 that they had not received any initial or ongoing advice from NAB Financial Planning for the 2013/14 financial year and up until December 2014 but had been charged $12,300.

The report said ASIC's investigations were continuing.

Another document, an email from ASIC to NAB in November 2017, slammed NAB's approach towards compensation for clients.

"We also note that the approach proposed by NAB is out of step with some of its major peers that have reported fees for no service failures and are close to finalising their customer review and remediation programs," ASIC senior executive Louise Macaulay wrote to NAB's general counsel, Sharon Cook.