- Members Portal
- ABA Website
Submissions
Download ABA Submission Guidelines (includes template and language)
Upcoming ABA Submissions Register
Read the calendar to stay up to date with upcoming ABA submissions.
Revisions to APS 220
2 February 2021 Private
The ABA’s key concern is that the proposed shortened implementation timeframe is not achievable. ADI’s are not able to implement a compliant APS 220 framework before 1 January 2022. The ABA suggests a staged implementation of APS 220 to deliver a more proportional response.
Download PDFReference Checking and Information Sharing Protocol (Consult 333)
29 January 2021 Private
Any new mandated protocol should be succinct and should build upon the efficiencies already established by licensees who are regularly involved in the request or provision of references, which would include Australian Financial Service Licensees (AFSLs) subscribed to the ABA Protocol. We would urge ASIC to review the information to be provided through the reference template.
Download PDFSubmission to the Payments System Review
22 January 2021 Private
The ABA strongly supports continuing the self-regulatory arrangements within our regulatory architecture. The payments regulatory architecture should support innovation, as well as ensure the stability, and security of an expanded payments ecosystem. Innovation in payments should be considered through the lens of consumer and business end-users. These users rightly expect that when they make a payment, whether this is done through traditional channels or via a new app, their payments will be made in a timely, safe and secure way and their data will be secure.
Download PDFAmendments to the Real Property Act 1886 (South Australia)
11 January 2021 Private
The ABA strongly supports the proposal to amend section 128 of the Real Property Act to permanently suspend the requirement that the corresponding mortgage be executed by the mortgagee. The ABA also strongly supports the proposal to amend section 153A of the Real Property Act to remove the requirement for the mortgagee to execute a corresponding mortgage.
Download PDFElectronic signing and remote witnessing of legal documents (Victoria)
8 January 2021 Private
The ABA welcomes the steps that the Victorian government has taken to support electronic transactions during the COVID-19 pandemic, and welcomes the proposals to make electronic execution reforms permanent.
Download PDFIFRS Submission to IBF on Sustainability Reporting
24 December 2020
The banking industry strongly supports efforts to establish a generally accepted international framework for sustainability reporting in order to promote consistency and comparability across organizations and reduce the potential for global fragmentation.
Download PDFDigital Identity Legislation: consultation paper
18 December 2020 Private
Banks are actively exploring digital identity initiatives and see the benefit of collaboration between government and industry. The interests of the Australian economy will be better served if there is flexibility to innovate and respond to the needs of consumers and businesses, instead of establishing a single government digital identity scheme. Government can also achieve genuine collaboration with industry without legislation.
Download PDFResponse to Senate Select Committee on Fintech and RegTech
17 December 2020 Private
The ABA urges the development of an overarching strategy for data and information privacy to underpin the transition to a digital economy and provide a consistent framework for future reforms. Co-ordination will be critical to achieve the intended outcomes. The data economy has the real and exciting potential to generate jobs and opportunities for servicing the needs of all Australians. Technology and digital capability are the mechanisms by which banking will continue to develop.
Download PDFSenate Select Committee on Financial Technology and Regulatory Technology
17 December 2020 Private
The ABA strongly recommends that any considerations which will liberalise the banking value chain by enabling execution of some functions by non-bank entities or individuals must first be passed through the lens of the objectives of the Reserve Bank and financial regulators so that security, safety, and privacy standards are maintained.
Download PDFPrivacy Act 1988 (Cth) Review
4 December 2020 Private
The ABA supports a review of the Privacy Act and the stated goals to ensure privacy settings empower consumers, protect consumer data, and best serve the Australian economy. Achieving the balance between Personal Information (PI) protection, innovation and economic growth will require considerable time and effort from the AGD to get these reforms right. The ABA urges the government to first design an overarching blueprint and roadmap for data and information privacy. The ABA highlights at multiple points that the OAIC could provide further and specific guidance rather than embedding the detail in the Privacy Act.
Download PDFABA approach to implementing APS 222
3 December 2020 Private
The ABA’s aim is to ensure a consistent approach to compliance is taken, to enable robust processes and systems to be developed to meet the compliance requirements and to avoid the high costs and disruption associated with unexpected changes close to the compliance date.
Download PDFSecurity Legislation Amendment (Critical Infrastructure) Bill 2020
27 November 2020 Private
The ABA proposes a small number of changes that would make these policy outcomes clear on the face of legislation and provide flexibility for the regime to address issues specific to one or more critical sectors. The ABA also reiterates that a harmonised approach, where a single regulator has a clear mandate and a transparent system in place for regulatory coordination, will ensure critical assets in the banking sector are secure and resilient.
Download PDFResponse to Treasury Consultation on Consumer Credit Reforms
24 November 2020 Private
The Australian Banking Association (ABA) supports the Government’s Consumer Credit Reforms. These important reforms will strike the right balance between maintaining strong consumer protections while providing credit into the economy at a critical time. The ABA supports: Maintaining strong consumer protections Consistent consumer protection and level playing field Simplification and removing duplication Support for complementary reforms
Download PDFInsolvency reforms to support small business – subordinate legislation
24 November 2020 Private
We are supportive of the aims of the Corporate Insolvency Reforms and encourage focus on achieving an appropriate balance for creditor protections.
Download PDFConsultation on confidentiality of key ADI metrics
20 November 2020 Private
An approach which supports APRA’s first proposal while overcoming the governance, timing and definitional issues outlined in this letter, is for APRA to publish only Level 2 capital, liquidity and asset quality items aligned with Pillar 3 after all entities have first disclosed the information to market. The ABA supports APRA publishing data on a quarterly basis which is already reported under Pillar 3 requirements. The ABA recommends APRA publish data only after ADIs have already disclosed it. The ABA recommends that before making any data non-confidential or public, APRA conduct their own audit of data definitions to identify and rectify any gaps in the taxonomy. The ABA recommends APRA only make non-confidential and publish Level 2 data. The ABA recommends APRA provide written reassurance that the specific items in the forms which are non-confidential but not proposed to be published, will not be published without further consultation.
Download PDF