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IBFed Submission to FSB on Climate
30 June 2022
This is the IBFed response to the FSB consultation on supervisory and regulatory approaches to climate-related risks. IBFed notes its concern with the timing of the public consultation given the multiple regulatory and supervisory requirements currently in place or pending implementation with specific data reporting. The submission also notes the multiplicity of consultations through the BCBS, NGFS, and ISSB in addition to national consultations. IBFed requests clarity as to how the FSB plans to use the findings of the report without duplication of other initiatives.
Download PDFAustralian Data Strategy
30 June 2022
The Australian Banking Association (ABA) welcomes the development of a unified strategy around the use of public and private data to drive economic, health and social outcomes. We are optimistic that all Australians will benefit from a coordinated government approach. ABA members encourage government to streamline their collection of data from banks, and encourage government to work with industry when developing future policies around data security and privacy and governance related to Artificial Intelligence.
Download PDFDirections for Data Collections
24 June 2022
The Australian Banking Association has responded to the Australian Prudential Regulation Authority’s (APRA) Directions for Data Collections and its associated five-year road map. The outline of APRA’s vision and the reasoning underpinning its strategy has allowed banks to start planning for and resourcing what is to be a major regulatory change, requiring significant investment. ABA members are now looking for the next level of detail on the future data collection, so they can start their own projects to ensure delivering to APRA’s timetables in the most efficient manner possible.
Download PDFAssisting customers without conventional ID
22 June 2022 Private
While the draft guidance assists in the types of documents REs can consider when providing services, we welcome further clarity on specific issues: – Circumstances where it would not be appropriate to provide services. – Risk rating of customers. – Reconfirming ID – Ongoing monitoring and Customer Due Diligence – Referee statements – Vulnerable customers – Business customers – Privacy
Download PDFTreasury: Quality of Advice Review
10 June 2022 Private
In this submission, the ABA makes recommendations that aim to strike a better balance between the need to provide access to advice, while ensuring effective consumer protections are in place. The ABA considers that improvements to the regulatory environment for financial advice could better support consumer outcomes at lower cost, which will benefit consumers and boost productivity.
Download PDFRevisions to the ADI Capital Framework
6 June 2022
The Australian Banking Association has provided feedback on the interim reporting standards and parallel run expectations for the ADI capital framework. This submission provides feedback on reporting timelines and dates, level of consolidation and scope of submissions as well as definitional questions relating to specific reporting standards
Download PDFCrypto Assets Secondary Services Licensing (CASSPr)
6 June 2022
Crypto assets ownership is increasingly mainstream in Australia. Banks are expecting to participate in the crypto sector in a range of roles. From this standpoint, the banking industry supports a clear and coherent regulatory framework for the crypto assets sector that helps to uplift standards. It is essential to provide greater legal certainty about when a crypto asset is a financial product, to give certainty to issuers of crypto assets and related service providers and to give consumers clarity about when a crypto asset is a regulated financial product.
Download PDFPragmatic implementation of APG 110, APG 112 and APG 113
31 May 2022
To assist consistency of implementation across the industry, the Australian Banking Association has developed industry position on a range of aspects regarding the implementation of APRA’s revised capital framework.
Download PDFAPS 117 Compliance Costs
24 May 2022
The ABA welcomes APRA’s ongoing engagement regarding the implementation of the revised APS 117 and provides the attached estimate of the associated compliance costs.
Download PDFAutomated Decision Making and AI Regulation
20 May 2022
Australian banks are using new technologies to increase efficiency and to provide new and more responsive services to customers. We propose the government focus on: simplifying or rationalising existing legislation that impact on the use of AI and ADM, in preference to new specific AI regulations; any regulatory intervention including setting best practice guidance should build on existing best practices and harmonise with sector specific regulation; and review and amend legislation to be neutral as to whether a human or technology is used to make decisions or conduct a process.
Download PDFNew South Wales Independent Flood Enquiry
20 May 2022 Private
The banking industry understands the importance of supporting customers and communities, both in the immediate aftermath of a natural disaster and on the road to recovery. The ABA welcomes the opportunity to provide a response to the New South Wales (NSW) Independent Flood Inquiry regarding the support banks in Australia provided during the 2022 flood disaster and suggested improvements for the future.
Download PDFStatutory Review of the Consumer Data Right
20 May 2022
The ABA makes a number of recommendations to improve the rollout of the Consumer Data Right, including prioritising changes that benefit consumers the most, simplify and streamline regulatory requirements and prioritise broader payments reforms before rolling out write-access.
Download PDFMandating eConveyancing in Queensland
5 May 2022
The Australian Banking Association continues to support efforts to accelerate the adoption of electronic mortgages and settlement for the convenience of consumers and the associated economic benefits. The banking industry is supportive of mandating electronic conveyancing in Queensland, which is a pragmatic and natural development from the current regime. Mandating e-conveyancing in Queensland will create greater certainty for consumers and drive greater efficiencies.
Download PDFABA Letter on PPG (110, 112, 113)
30 April 2022
To assist APRA finalise the prudential practice guides (APG 110, APG 112 and APG 113), industry provides the attached feedback in response to: 1) the materials presented to the industry in the APRA-ABA workshop on 8 April; and 2) the subsequent queries to industry on 19 April.
Download PDFJoint ABA-ICA letter: crisis resolution – policy development
29 April 2022 Private
The banking and insurance industries are supportive of APRA’s objective to establish this policy framework. We recognise the desirability of the orderly resolution of a regulated entity in the extremely rare event of its business failure and that any losses should preferably fall on debt and equity investors. However, we feel that the process by which APRA’s resolution policy framework is being developed should be modified to allow for greater industry engagement, to reduce uncertainties and to reduce the regulatory burden, particularly of entities selected in future pilot exercises.
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