Submission to APRA on a three-tiered framework

The ABA welcomes APRA’s explicit recognition of the capacity for better calibrated capital settings to support economic growth without compromising financial stability. We encourage APRA to continue to identify options to support further economic growth.

The ABA supports APRA’s objectives for good governance as reflected in the draft CPS 510.
The ABA notes, however, that the draft in several places takes a more prescriptive approach
than the current version of CPS 510, and that this may unnecessarily restrict entities’ flexibility
in how they arrive at desired outcomes.