"Recent disclosures to the banking royal commission indicate that a review which is commissioned and paid for by a board, with terms of reference set by that board and a reporting process that has a closed loop back to the same board, will be viewed with cynicism," Dyer wrote in the ACA's Onside magazine.
"The review's success and its broad acceptance as being truly independent will therefore be conditional on absolute transparency.
"Organisational culture begins at the top and it is our view that the board commissioning this review should themselves be subject to proper scrutiny and open findings.
"It will be imperative that we are all able to see the process, the findings and the recommendations for change, in full and frank disclosure."
The ACA reiterated its concern at the "disproportionate" penalties handed out to former leaders Steve Smith and David Warner, who were banned for 12 months, and opener Cameron Bancroft, who has been suspended for nine months.