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Digital Identity Position Paper (Phase 2)
16 July 2021
ABA reiterates our view that there is significant potential economic benefit in the government’s digital identity initiative for consumers and businesses. ABA also reiterates that the ability of a government digital identity system to achieve wider adoption, and therefore realise the potential economic benefits of this government policy, will likely depend on factors such as clarity of legislative framework, flexibility to innovate and incentive to participate, security of protections for data and privacy, and clarity and effectiveness of governance arrangements.
Download PDFUsing technology to hold meetings and sign and send documents
16 July 2021
The ABA supports legislation being technology neutral and facilitating innovation in how companies and businesses engage with shareholders and other stakeholders.
Download PDFReview of Retail Payments Regulation Consultation Paper
12 July 2021
ABA supports the RBA taking a considered approach on retail payments issues set out in this consultation. ABA agrees with the RBA maintaining policy focus on least cost routing (LCR) / merchant choice routing (MCR), and welcomes the opportunity for industry to work with the RBA to apply these concepts to online payments. ABA supports the RBA’s forward-looking focus on issues as buy now pay later (BNPL) and digital wallets.
Download PDFNational Register of Enduring Powers of Attorney
9 July 2021 Private
The ABA has advocated for the national register to be part of a longer-term plan for reform to combat elder abuse which would include harmonisation of laws across the states and territories, a national education campaign, and designated authorities which can investigate suspected elder abuse.
Download PDFReporting Standard ARS 220.0 Credit Exposures and Provisions (APRA)
6 July 2021
The ABA and members are supportive of APRA’s move to data collection based on a concept-dimension data model. ABA members broadly support the approach APRA has outlined in their letter of June 8. The collective view of ABA members is that a successful implementation will result from sufficient time being given to develop a full taxonomy, and that this is finalised well in advance of the first submission date so banks can build the infrastructure to support the data model. ABA members have concerns with the overlap of two new reporting requirements (the tactical solution and the incremental collections), the granular level of detail required for the strategic solution (especially for the lower risk portfolios) and the timing by which each reporting needs to be provided.
Download PDFReview of the ePayments Code: further consultation (CP341)
2 July 2021
The ABA supports proposals to clarify the definition of a mistaken internet payment (MIP), Further work is needed to assess the case and benefits of the proposal to extend the ePC to small business. While ABA supports modernising the Code, we consider the proposals about biometrics and virtual cards need further work. ABA also asks ASIC to consider a more fulsome modernisation of the Code.
Download PDFAustralia as a Technology and Financial Centre – Issues Paper
30 June 2021
The ABA welcomes the G20 support for FATF action on the regulation and oversight of virtual assets and virtual asset service providers. The ABA supports Australia’s adoption of FATF Standards to support responsible innovation across the financial services sector.
Download PDFRG 271: Internal Dispute Resolution
25 June 2021 Private
The ABA is supportive of the proposed amendments, subject to the recommendations to incorporate a minor amendment to RG 271 to clarify that ‘time stops running’ between when a complaint is closed without an IDR response and when the complainant subsequently notifies the financial firm that they wish to escalate the complaint within the bank,… Read more »
Download PDFRegulation of credit cards and digital wallets for online gambling
25 June 2021
The ABA encourages the Committee to consider amending the Interactive Gambling Act 2001 to establish a consistent policy approach to the use of credit for gambling across all gambling services in venues and online for the benefit of customers. Banks will continue to engage with community groups and industry stakeholders on this issue.
Download PDF2021 Credit Reporting Code Consultation
21 June 2021 Private
The ABA requests that ARCA reconsider its proposed approach to the treatment of payment test and catch-up periods in circumstances where the arrangement follows a non-contractual FHA. This scenario is a common one for many consumers being managed by many credit providers’ hardship teams. For example, banks may offer payment test periods to customers after… Read more »
Download PDFProposed Financial Institutions Supervisory Levies for 2021-22
11 June 2021 Private
The ABA requests Treasury give further consideration both to the funding request of the financial regulator and the methodology that has been used to apply cost recovery across the sector. It is our view that the current cost recovery model imposes a significant burden on mid-sized ADIs.
Download PDFPhase 1.5 AML/CTF Rules and Guidance
8 June 2021
The ABA strongly supports the objectives of the AML/CTF regime. It also strongly supports that the obligations be simplified, streamlined and clarified, and the regulatory burden reduced where possible. While we are supportive of these amendments overall, the ABA seeks clarification on aspects of the draft Rules and Guidance.
Download PDFConsultation on BCCC Operating Procedures
8 June 2021
Key points – Remediation (clarity required), Naming sanction (should be at the severe end of the range), Timeliness (critical).
Download PDFConsultation Paper 340: ASIC breach reporting and related obligations
3 June 2021
It is vital that policymakers and regulators implement the regime prudently, if it is to be effective in achieving its aims, and viable from the perspective of implementation by the sector. The ABA has key recommendations, requires confirmations and further clarity on breach reporting and related obligations coming into effect 1 October 2021 in these particular areas: Avoiding duplication Clarity over legal definitions The scope of an investigation Treatment of criminal offences Examples of breaches of deemed significance Reporting of multiple breaches related to a single cause or systemic issue Regulatory portal
Download PDFPM&C – Regulator Performance Guide
2 June 2021
The ABA considers that the review of the existing Regulator Performance Guide is timely. It is critical to ensure that regulation of the financial system does not inhibit the ability of financial firms to serve the Australian population or grow the economy. The ABA supports the Government’s proposal to transition towards a more flexible and principles-based approach to regulator performance. We have developed our response with a focus on providing constructive suggestions to improve the potential scope and application of the three principles that are proposed with regard to financial regulation Continuous improvement and building trust Risk-based and data-driven Collaboration and engagement
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