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Read the calendar to stay up to date with upcoming ABA submissions.
Critical Infrastructure Protection Bill
1 March 2022
The ABA welcomes the steps the Government is taking to work with critical industries to enhance industries’ operational and cyber resilience. ABA members already cooperate with the relevant Government agencies and with the Council of Financial Regulators (CFR) on cyber security matters and we look forward to strengthening those partnerships. ABA has identified a number of implementation issues or issues that are likely to require further legislative amendment. ABA proposes a two-year statutory review of the significant amendments introduced to the Security of Critical Infrastructure Act 2018.
Download PDFSupporting business adoption of electronic invoicing (BER)
25 February 2022
The ABA provides feedback to Treasury regarding the proposal to introduce a Business EInvoicing Right to accelerate business adoption of Peppol international eProcurement framework. The ABA strongly supports initiatives aimed at increasing business awareness and accelerating the adoption of eInvoicing; however, considers it premature to mandate a BER at this point in time.
Download PDFFarm Debt Mediation
25 February 2022
The Australian Banking Association (ABA) welcomes the opportunity to provide feedback on the proposed better practice guide for Farm Debt Mediation (FDM).
Download PDFMacroprudential and APS 220
25 February 2022
Increasing the macroprudential policy options available to APRA and transparency regarding when and how they may be used, should assist with enhancing the financial stability and resilience of the Australian economy. The ABA is supportive of these measures which offer a useful complement to the resilience provided by Australia’s well capitalised and well managed banks. In developing and implementing market interventions, such as macroprudential policies, it is vitally important that unintended consequences, regulatory burden and competition distortions are minimised. As such, and considering the system wide consequences of macroprudential interventions, the ABA strongly recommends APRA incorporates and imbeds processes to ensure early and close engagement with the banking industry before any macroprudential policies are implemented. Additional recommendations and points for clarification are included in the ABA’s submission to APRA.
Download PDFDe-banking – Draft AUSTRAC Guidance
21 February 2022 Private
The ABA makes comment on AUSTRACs proposed guidance for providing services to remitters, digital currency exchanges and other fintechs subject to AUSTRAC regulations.
Download PDFIBFed Climate-related Financial Risks
16 February 2022
This is an IBFed submission to the BCBS’s consultation on the draft Principles for the effective management and supervision of climate-related financial risks. The ABA is a signatory to this submission.
Download PDFCP 350 Consumer remediation: Further consultation
15 February 2022 Private
The ABA provides feedback on ASIC’s consultation on revised draft guidance for consumer remediation (CP 350)
Download PDFReview of the Privacy (Credit Report) Code 2014
11 February 2022
The ABA generally considers that the CR Code works well to meet the competing objectives of privacy versus economic effectiveness.
Download PDFAASB ITC 46AASB Agenda Consultation 2022-2026
8 February 2022 Private
This submission responds to the AASBs proposed 2022-26 agenda and recommends that Climate and nature based reporting be given prominence in the forward workplan.
Download PDFBCCC Priorities for 2022-23
8 February 2022
The ABA provides input to the Banking Code Compliance Committee (BCCC) consultation on its 2022-23 compliance priorities. In addition to its response on the six consultation questions, the ABA acknowledges the critical role the BCCC plays in both monitoring and enforcing banking sector compliance with the Banking Code of Practice and identifying best practice for banks to help achieve compliance in the best interests of customers. The ABA also acknowledges the BCCC submission to the Banking Code Triennial Review and looks forward to working closely as the ABA leads the development of an updated Code.
Download PDFAASB ITC 48 Extended External Reporting
7 February 2022
This submission responds to the Australian Accounting Standards Board consultation on extended external reporting (ITC 48.)
Download PDFFRAA ASIC Assessment
1 February 2022 Private
The ABA provides general and specific feedback to the Financial Regulator Assessment Authority on the performance of ASIC, particularly in relation to its strategic prioritisation and decision-making.
Download PDFCP354 Simple Hardship Arrangements
1 February 2022
The ABA requests confirmation from ASIC that a temporary financial hardship arrangement agreed under the Credit Reporting Code does not require a credit provider to send a ‘rejection notice’ under section 72(4)(b) of the National Credit Code. Once ASIC provides this confirmation, we consider that there is no real need for the continuation of the simple arrangement exemption in its current form.
Download PDFCritical Infrastructure – Bill Two and Application Rules
1 February 2022 Private
The ABA has made several recommendations, is in general agreement with some key aspects, but seeks clarity on particular points, and is waiting on further details included in proposed amendments.
Download PDFAUSTRAC levy
28 January 2022 Private
The ABA continues to raise concerns over the inequitable and opaque AUSTRAC industry levy and seeks further clarity on the manner it is calculated and seeks to improve the basis upon which it is levied.
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