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National Reconstruction Fund: consultation paper
1 February 2023
The Australian Banking Association (ABA) supports the intent of the National Energy Performance Strategy. The ABA considers that enhancements to building codes and regulations, coupled with decarbonising the grid, can be an effective way to support improvements to energy performance. We also advocate for the provision of rebates, tax incentives and subsidies to support the adoption of energy efficiency technologies, particularly in relation to individuals from low-income households who may not have the capacity to fund energy efficiency upgrades.
Download PDFADI centralised publication update and consultation
31 January 2023
ABA supports APRA’s decision to limit the first stage of ADI data publication to metrics which are aligned with bank Pillar 3 disclosures, while also noting there are some metrics which are not wholly consistent with these bank disclosures. Given the limited number metrics to be published, in contrast to the original proposal, ABA is comfortable with immediate publication on a quarterly frequency from June 2023.
Download PDFHousing Legislative Package
11 January 2023
The ABA supports the Housing Legislative Package and the establishment of the Housing Australia Future Fund as a mechanism to provide a sustainable funding source to support and increase the development of social and affordable housing. The Housing Legislative Package should also assist in alleviating critical affordable housing needs for frontline workers, older women on low incomes, family and domestic violence survivors and First Nations communities. Australian banks have worked closely with non-profits and Government over recent years to support the social housing sector. The ABA and banks offer to work closely with the Government and other key stakeholders during the development of the investment mandate for Housing Australia to ensure it aligns with the previous recommendations of the Statutory Review of the Operation of the NHFIC Act 2018, including those relating to ‘crowding-in’ financiers. The ABA also recommends that Government consider expanding the current appointments of the National Housing Supply and Affordability Council to include members with a strong banking or lending background.
Download PDFRegulating Buy-Now, Pay-Later in Australia
23 December 2022
Buy Now, Pay Later products cannot be considered without also considering the broader regulation of credit and credit-like products. We agree with the Minister for Financial Services and Assistant Treasurer, the Hon Stephen Jones MP, that BNPL and other credit products are often indistinguishable from a consumer’s perspective and yet the regulatory oversight of the former is substantially weaker. Any difference in the regulatory treatment of BNPL from other credit products should have a clear, evidence-based policy justification.
Download PDFProviding Financial Services to Customers that Financial Institutions Assess to be Higher-Risk
21 December 2022 Private
The ABA recommends AUSTRAC pause the finalisation of their de-banking guidance until the government response to the Council of Financial Regulators is finalised, in light of recommendations that could have implications for the operation of AML/CTF laws.
Download PDFMultinational tax integrity: Public Beneficial Ownership Register
19 December 2022
The ABA supports the implementation of a beneficial ownership register that is centralised, includes trusts and other entity types from the outset and a clear focus on the different policy goals.
Download PDFEmpowering the AASB to Deliver Sustainability Standards
16 December 2022
The Treasury is consulting on clarifying the powers of various entities in the Australian financial reporting system to include the development and assurance of sustainability standards. The ABA supports the draft legislation to the extent that it allows the alignment of Australian accounting standards with global standards, noting that further consideration is needed to identify appropriate long-term governance arrangements.
Download PDFModernising the Prudential Architecture
16 December 2022
The ABA welcomes APRA’s engagement on and initiatives regarding modernising the prudential architecture. The ABA is very supportive of this multi-year initiative and remains available to assist APRA develop a more interactive, efficient, effective and future proof prudential architecture.
Download PDFEnhanced Customer Due Diligence/ Employee Due Diligence Guidelines Government
16 December 2022 Private
Enhanced Customer Due Diligence. As part of your initial customer due diligence processes and ongoing monitoring of your customers and their transactions, you must be able to identify whether the money laundering and terrorism financing (ML/TF) risk posed by a customer, the business relationship or transaction(s) is high. Where the risk is identified as high, you must apply enhanced customer due diligence (ECDD) procedures to understand, mitigate and manage the ML/TF risks. Employee Due Diligence. Employee due diligence means screening your employees to make sure they do not pose a money laundering or terrorism financing (ML/TF) risk to your business.
Download PDFProperty Law Act Review
15 December 2022
The Australian Banking Association (ABA) welcomes the opportunity to provide further feedback on the Queensland Government’s consultation on the Property Law Bill 2022 and Property Law Regulation 2023. The ABA supports some of the revisions to the latest draft of the Bill but remains of the view that flood history data should be contained within the seller’s disclosure statement, particularly in light of repeated flooding events across Australia. It also has concerns with directing prospective buyers to the FloodCheck Queensland and Australian Flood Risk Information portals, where information may be incomplete or incorrect, to understand the flooding history of a property.
Download PDFDraft RCTI Legislative Instrument and Explanatory Statement
15 December 2022 Private
The ABA is responding the Draft Legislative Instrument on Recipient Created Tax Invoices (RCTIs). RCTIs are an important feature of the GST regulatory framework that enable Australia businesses to efficiently invoice supplier. The ABA understands the ATO has identified instances where there has been a failure by suppliers to remain registered for GST whilst continuing to receive payment for services supplied when registered for GTS. The current draft LI will remove the efficiency of RCTIs, is impractical, and unworkable.
Download PDFStrengthening crisis preparedness
6 December 2022
The banking industry is supportive of the APRA’s ongoing crisis preparedness reforms which are aimed at ensuring both entities and APRA are prepared to deal with threats to institutions’ viability. This complements the rigorous prudential, legal and regulatory regimes already in place, and banks’ strong management and unquestionably strong capital positions.
Download PDFData Quality Compliance in the Consumer Data Right
2 December 2022 Private
The ABA submits that data quality is a key priority for member banks and that as the CDR continues to mature many of the data quality issues are likely to be resolved. We suggest key improvements to the incident management system, to categorise, standardise and prioritise incidents as they arise so there is an ability to address key issues from the outset.
Download PDFALRC Interim Report B
30 November 2022
The Australian Banking Association (ABA) on behalf of its members welcomes the opportunity to make a submission to the Australian Law Reform Commission regarding Interim Report B on Financial Services Legislation. The ABA welcomes the Report, including the attempt at simplifying the structure of the Corporations Act. In its response, the ABA emphasises the importance of adequate consultation with stakeholders throughout the process, as well as adequate time for financial services entities to transition and implement any amendments.
Download PDFCorporate Insolvency
30 November 2022
The Australian Banking Association (ABA) on behalf of its members welcomes the opportunity to make a submission to the Parliamentary Joint Commitee on Corporations and Financial Services regarding the terms of reference for the Inquiry into Corporate Insolvency in Australia. The ABA welcomes the review and the proposed terms of reference. The ABA suggests that the review focus on improving access to insolvency processes, particularly for small business, and that the review has regard to overseas experiences such as Singapore and the United Kingdom.
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