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Australian Government Drought Plan
30 September 2022 Private
Banks in Australia recognise that drought in Australia is not a new phenomenon, and the focus on drought should not be restricted to times of drought. Drought will continue to be an enduring, challenging experience and a feature of the Australian lands cape for which preparation is needed. The ABA remains supportive of the Australian Government having a drought plan, focusing on long term preparedness and resilience activities to ensure farmers and communities in Australia are adequately prepared when the next drought occurs.
Download PDFTasmanian Land Titles Bill
29 September 2022
The Australian Banking Association (ABA) welcomes the Department of Natural Resources and Environment Tasmania’s engagement with industry regarding the proposed amendment to the Land Titles Act 1980. The ABA and its members are broadly supportive of the proposed amendment but make two observations for the Land Titles Office’s consideration.
Download PDFSafeguard Mechanism Reforms
23 September 2022
ABA notes the Safeguard mechanism is a core element of the Powering Australia plan. We support the reform of the SGM in so that it can play its role in achieving the nation’s net zero goals. We also encourage the government to develop or curate and endorse national science-based sectoral decarbonisation pathways.
Download PDFVoluntary Biodiversity Market
21 September 2022
Banks in Australia are generally supportive of nature-related markets, payments for ecosystem services and providing incentives to landholders to create positive outcomes for nature. Voluntary private sector investment can, and does, make a significant contribution to nature and having a regulated market-based approach can help scale up investment activities with conservation and nature positive outcomes. Voluntary private sector investment would need to be accompanied by public investment and national environmental reform.
Download PDFAPRA’s Strengthening Operational Risk Management Requirements
21 September 2022
The ABA is supportive of the proposal to replace CPS 231 Outsourcing (CPS 231) and CPS 232 Business Continuity Management (CPS 232) with a new CPS 230. Bringing together these related concepts into a single standard should support a more holistic approach to operational risk management. However, the ABA is concerned that, as currently drafted, the proposed changes will not result in materially better operational risk outcomes despite adding significant additional regulatory burden through increased costs, resourcing, tooling, oversight and compliance in the ‘design, implement and run’ phases, including impacts to participants on banks’ supply chains.
Download PDFReview of the Farm Business Debt Mediation Act 2017 (Qld)
2 September 2022 Private
The current provision of documents outlined the Act can distract from the purpose of the mediation and result in additional complexity/duplication of documents, creates uncertainty as to the scope of documents and adds costs to the farmer.
Download PDFNSW organised crime reforms
2 September 2022 Private
The ABA flags serious concerns with proposed reforms by the NSW police to freeze and request information on persons of interest for a criminal investigation. We note the need for early engagement and the need to ensure appropriate checks and balances are in place, including ensuring a court order is required to freeze accounts. We also note the need to protect the privacy and security of customer data where they are not the subject of an investigation.
Download PDFRemoval of duplicate certificates of title in WA in 2023
29 August 2022
The ABA and its members are supportive of Landgate’s proposal and timeline to reduce the duplication of documents.
Download PDFAPRA Finalising Bank Capital Requirements
26 August 2022
The Australian Banking Association welcomes the Australian Prudential Regulation Authority’s ongoing engagement with industry regarding the development of the revised capital framework including the consequential amendments to Liquidity, Securitisation and Counterparty Credit Risk and the release of the final Prudential Practice Guides for bank capital – APG 110, APG 112 and APG 113 – and the updated prudential standard, APS 113. While the release of the finalised PPGs (and associated standards) marks a milestone in the development and implementation of the revised capital framework (Basel 3.5), considerable work remains over the coming years to: imbed the changes; develop and implement reporting capabilities; and educate industry observers, commentators and participants about the new capital and reporting requirements. The ABA provides comments for APRA’s consideration which cover both the consequential amendments and the capital framework package more broadly.
Download PDFAUSTRAC debanking consult
19 August 2022 Private
Australian banks support an innovative financial services sector and understands the critical role that access to finance plays in supporting new and emerging sectors, and generally for higher-risk customers. We understand the detrimental impact that de-banking can have on businesses and continue to balance the important role banks play in providing access to finance to businesses in all sectors while protecting the financial system and their customers from criminal exploitation. This submission makes recommendations on ways the regulator can assist banks to ensure more customers in high-risk sectors can receive services.
Download PDFELNOs Interoperability Pricing Issues Paper July 2022
12 August 2022
The ABA and its members remain supportive of the realisation of a functioning interoperable e-conveyancing market. A functioning interoperable e-conveyancing market should benefit subscribers and other stakeholders, including everyday Australians. The ABA and its members encourage IPART to consider the implications of its recommendations on all e-conveyancing market participants, paying particular attention to the potential cost consequences of subscribers, some of which have little negotiating power.
Download PDFNSW E-Conveyancing Enforcement Regime
3 August 2022 Private
The ABA and its members remain supportive of the realisation of a functioning interoperable e-conveyancing market. We are also supportive of the ORG’s proposal to develop and implement an enforcement regime in NSW for e-conveyancing.
Download PDFFarm Debt Mediation Better Practice Guide Consultation
19 July 2022
The ABA acknowledges the challenges experienced to date in implementing uniform farm debt mediation (FDM) legislation nationally however, despite these challenges, the ABA position remains that farmers across Australia should have access to the same safeguards and support regardless of their postcode.
Download PDFAASB ED 321 Request for Common on [Draft] IFRS S1 and [Draft] IFRS S2
15 July 2022
ABA position on the IFRS Foundations ISSB proposed financial disclosures
Download PDFAASB request reply on ISSB IFRS Submission
15 July 2022
The ABA supports a global approach to the development of sustainability disclosure standards through the ISSB as the global body to issue the standards. Further, the establishment of a global baseline is critical a coordinated approach be developed which will avoid fragmentation in reporting obligations. To this end we support the efforts of the ISSB in establishing a working group to enhance compatibility between global baseline and jurisdictional initiatives.
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