So just how much will the banks' bad behaviour unearthed at the financial services royal commission cost them? $2 billion? $3 billion? How about $7.4 billion?

That's the figure veteran bank analyst Brett Le Mesurier from Shaw and Partners has come up with after a flurry of confessions leading into the banks' mini reporting season.

NAB's announcement of a new $314 million hit to its second half earnings appears to be one of the last disclosures for now. But it won't be the last.

The cost of bad behaviour

Company Prior costs H2 2018 costs (est) H1 2019 costs (est) Total (est) AMP $517m $83m $570m $1,170m ANZ $340m $573m $470m $1,383m CBA $2,257m * $320m $2,577m NAB $300m $450m $350m $1,100 WBC $384m $376m $410m $1,150m Total $3,779m $1,480 $2,100m $7,379m

* CBA has already released H2 2018 results & treated as "prior". Source: Shaw and Partners, companies

Mr Le Mesurier said the cost would rise significantly from the $3.8 billion already forked out by the banks and AMP.

"The banks still haven't uncovered everything, it's an ongoing process," he said.

"They still have teams going through all the products and advice that have been sold."

But is the first half of 2019 the end?

"There may be another column, but it should be enough ... beyond then the costs should be less material, hopefully," Mr Le Mesurier said.

"However, you look at CBA, they've gone back eight years so far and they are still finding stuff."

Cost of bad behaviour by item*

Prior costs H2 2018 costs (est) H1 2019 costs (est) Total (est) No advice provided $474m $239m $423m $1,136m Poor advice provided $358m $326m $417m $1,101m Product reviews $577m $274m $140m $991m Total refunds $1,409m $839m $980m $3,228m Implementation costs $771m $440m $630m $1,841m Risk and compliance $555m $107m $210m $872m Royal commission, regulatory, litigation $1,043m $94m $300m $1,437m Total $3,779m $1,480m $2,120m $7,379

*Estimates are pre-tax Source: Shaw and Partners, companies

Mr Le Mesurier said while the cost of customer refunds was expected to be around $3.2 billion, the cost of implementing the programs to determine these refunds was expected to be $1.8 billion.

"Such costs indicate how poor the banks' controls and systems have been," he said.

The bulk of more than $3 billion implementation, litigation and risk and compliance costs can be laid squarely at the feet of CBA's almost $1.9 billion contribution.

"CBA's number is so large because they have been in remediation mode for a number of years and they have to settle the [$700 million] AUSTRAC litigation, Mr Le Mesurier said .

Customer refunds for no and poor advice

FY18F and

prior refunds FY19 refunds

forecast Total refunds No. of

planners Refund per

planner AMP $414m $320m $734m 2,700 $272,000 ANZ $186m $100m $286m 1,000 $286,000 CBA $270m $100m $370m 1,660 $223,000 NAB $331m $130m $461m 1,600 $228,000 WBC $197m $190m $387m 1,000 $387,000 Total $1,398m $840m $2,237m 7,960 $274,000

Source: Shaw and Partners, companies

Perhaps the most striking feature of Mr Le Mesurier's analysis is how much planners were paid for doing either next to nothing, or just doing their jobs badly.

The average refund per planner liable to be paid comes in at $274,000. Westpac's in-house and aligned planners appear to have generated the largest refund per head of almost $400,000.

Mr Le Mesurier said the most polite thing you could say was the average refund per planner was an "extraordinary" sum.

"It seems that AMP has the greatest potential for further customer refunds," he said.

"One issue for the industry is how much they might recover from their aligned planners."