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ABA 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.
Download PDFStrengthening crisis preparedness
29 April 2022 Private
The banking industry is supportive of Australian Prudential Regulation Authority’s (APRA) crisis preparedness reforms which are aimed at ensuring entities are prepared to deal with threats to their viability. This complements the rigorous prudential, legal and regulatory regimes already in place, and banks’ strong management and unquestionably strong capital positions. The APRA-ABA roundtable discussions have assisted industry’s understanding of APRA’s intent with the draft standards. Industry, however, feels that greater industry engagement is required for these significant and potentially very impactful reforms, particularly CPS 900.
Download PDFAPRA – IRRBB Volatility
28 April 2022
The industry has four main concerns regarding IRRBB volatility and two simple proposals which would address these concerns.
Download PDFIndependent Health Checks and Readiness Assessments of the Interoperability Reform
21 April 2022
The ABA is supportive of implementing ongoing and independent health checks, to review the risks to and status of the national roll-out of interoperability. The banking industry is also supportive of the proposed three phase approach.
Download PDFAUSTRAC guidance on source of funds and source of wealth
14 April 2022
The ABA supports AUSTRAC guidance that sets clear regulator expectations on the obligations placed on Reporting Entities (REs). Banks welcome clarity on AUSTRAC’s expectations regarding when an entity may conduct source of funds and source of wealth checks in light of the draft guidance.
Download PDFExtension of the Consumer Data Right to non-bank lending
14 April 2022
Response to Treasury’s consultation on the extension of the Consumer Data Right to non-bank lending. In this submission, the ABA responds to some issues raised in the discussion paper and provides comment based on the experience of banks in implementing the CDR.
Download PDFBasel III liquidity ratios: post-implementation review
14 April 2022
The LCR and NSFR were and remain important elements of the Basel III Liquidity reforms. Overall, these liquidity measures have achieved their objectives of promoting short-term and long-term resilience of banks’ liquidity and funding profiles and are supported by the banking industry.
Download PDFClimate Change Authority International Offsets
14 April 2022
The ABA encourages continuous improvement in the operating features of carbon markets to improve integrity and trust and to build scale and liquidity.
Download PDFFarm Debt Mediation (QLD)
25 March 2022
Farm Debt Mediation (FDM) is widely acknowledged as a successful way for the farmer and the financier to resolve matters relating to farm business debts and, in many cases, is a preferred alternative to court. Most importantly, the FDM process provides an additional avenue for farmers in financial difficulty to either re-establish and maintain their viability or exit the industry with dignity. The ABA welcomes the review’s consideration of opportunities to enhance the Act and align with legislation in other states where possible.
Download PDFAPRA: Capital Framework Revisions Draft Guidance
14 March 2022
The ABA continues to support a revised capital framework that strengthens the financial resilience of the industry, embeds the industry’s unquestionably strong level of capital and provides for greater flexibility in periods of stress. ABA member banks are actively working towards the implementation of APRA’s revised capital framework. Considerable work still remains in both defining and implementing the framework based on the practice guides issued as well as implementing related changes to regulatory reporting, modifications to Pillar 3 and international comparability studies, and updates to related standards.
Download PDFElectronic Conveyancing National Law
11 March 2022
The Australian Banking Association (ABA) continues to support efforts to accelerate the adoption of electronic mortgages for the convenience of consumers and the associated economic benefits. The ABA and its members have actively contributed to the development of e-conveyancing since its infancy as well as interoperability and the associated reforms. The banking industry is supportive of progressing the Electronic Conveyancing National Law to implement interoperability, with further consultation to consider in detail the issues that ABA and other stakeholders have raised. This 2-step process is a pragmatic response to the complexity of the reform, and the need to balance certainty of the reforms with addressing important issues that stakeholders have raised.
Download PDFAPRA: Strengthening crisis preparedness
9 March 2022
The banking industry is broadly supportive of the Australian Prudential Regulation Authority’s proposals to strengthen crisis preparedness across the finance industry. This should increase the safety and stability of Australia’s financial system and complements the rigorous prudential, legal and regulatory regimes already in place, and banks’ strong management and unquestionably strong capital positions.
Download PDFBankruptcy system options paper
8 March 2022 Private
While the ABA sets out its specific responses to the possible changes below, we encourage the Government to consider these changes in the context of the broad suite of reforms made or proposed in recent years that potentially change the consequences of insolvency for companies and bankruptcy for individuals. This includes small business insolvency reforms, changes to schemes of arrangement and the review of the safe harbour regime.
Download PDFAG: Bankruptcy system options paper
8 March 2022
The ABA provides feedback to the Attorney-General’s Department on the Bankruptcy system options paper and encourages the Government to consider these changes in the context of the broad suite of reforms made or proposed in recent years that potentially change the consequences of insolvency for companies and bankruptcy for individuals. This includes small business insolvency reforms, changes to schemes of arrangement and the review of the safe harbour regime. The ABA also highlights the need for Government and policymakers to consider how these reforms may impact the flow of credit to small businesses and the effect of this on commercial activity with the aim of striking the right balance between creditors and debtors.
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