ANZ has rejected suggestions it was not prepared to deal with significant numbers of farmers facing hard times after its Landmark acquisition.
The bank has acknowledged shortcomings in its conduct in relation to some former Landmark customers but does not want the banking royal commission to draw broader conclusions.
Counsel assisting the inquiry suggested the conduct could be attributed to ANZ's lack of preparation for a situation requiring it to deal with significant numbers of agribusiness customers experiencing financial difficulties and the culture in its lending services division before changes in 2014.
ANZ rejected those proposed findings, noting the commission only examined 12 customer groups among the 4500 customers it took on when it bought the Landmark Financial Services loan book in 2010.
"There is no basis for concluding that they are in any way representative of the treatment of the entire loan book as a whole," it said in a submission released on Tuesday.
The inquiry heard a significant number of former Landmark customers felt they were treated unfairly by ANZ.
But the bank said it received relatively few complaints - 71 between 2010 and 2017.
ANZ said there was no evidence to conclude the conduct affected a broader customer group, nor was it attributable to broader cultural considerations.
"Nor does the evidence support a connection between any lack of preparation by ANZ to receive new Landmark customers in 2010 and the conduct about which the commission has heard evidence."
ANZ accepted its conduct fell below community standards and expectations or amounted to misconduct - by breaching the code of banking practice - in particular cases.
Examples included poor communication, failing to honour a client's cheque, a delay in making funding available, not accepting a reasonable settlement offer and not taking sufficient steps to assess the suitability of a guarantor.
ANZ paid $40 million in total to 40 to 50 former Landmark customers, through debt forgiveness or compensation.
National Australia Bank, which was among other lenders criticised by counsel assisting over their dealings with particular farmers, defended charging struggling Queensland graziers more than $2.6 million in default interest over more than five years for missed loan payments.
The bank has allowed the drought-stricken cattle farmers to keep their two properties but default and ordinary interest continues to be charged.
NAB rejected suggestions its conduct fell below community standards, adding it still wanted a mediated resolution that allowed the couple to keep one of their farms and have cattle to earn an income, while getting relief from the default interest so they could refinance.
