ANZ will commission an expert review of the ANZ Custodial Services business and will have 14 months to finalise changes within the business recommended by this expert, the bank has agreed with ASIC.The Australian Securities and Investments Commission said on Friday that ANZ agreed to an enforceable undertaking following an ASIC investigation into the bank's securities lending activities.ASIC contends that ANZ operated an unregistered managed investment scheme between about 26 July 2006 and 27 March 2008 (when Opes Prime collapse).ANZ does not fully concede this point, with ANZ accepting that deficiencies existed only since October 2007, or the final five months of the life of Opes Prime. ANZ had operated a securities lending business for more than six years at this stage.The bank undertook its own review of securities lending, published in August 2008, or five months after the collapse of Opes Prime. The chief findings of that review were the pattern of incompetence and the shirking of management responsibility for follow up on matters raised in internal audit reports.However, the issue of whether ANZ needed to register a managed investment scheme was one topic not addressed in the securities lending review.The chief burden of the enforceable undertaking for ANZ is the additional cost to allow yet another expert and ASIC look over the remedial work it is already doing.Another burden, though, is the additional damage to ANZ's reputation from the affair, if any.