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CDR Rules consultation Combined Accredited Persons Arrangements
29 July 2020 Private
The main instruments of the CDR, the Rules and the standards, do not capture the significant underlying complexity in implementation and ongoing operations of the CDR. The ABA strongly encourages the ACCC to develop detailed explanatory documentation to accompany the Rules which will act as an interpretive bridge from which the standards and the business processes of the CDR participants can be developed.
Download PDFInquiry into family, domestic and sexual violence
24 July 2020
The banking industry is committed to working with government and stakeholders to develop workable and effective strategies and policy solutions to support those impacted by family, domestic and sexual violence related financial abuse.
Download PDFDraft Goods and Services Tax Ruling GSTD 2020/D1
20 July 2020 Private
The preliminary views and conclusions expressed in GSTD 2020/D1 are very concerning to the ABA. In particular, and in line with our views as expressed in our previous submissions to GSTD 2014/D12, GSTD 2018/D13 and GSTR 2019/D14, we continue to have significant reservations about the Commissioner’s interpretation and application of the relevant GST provisions.
Download PDFBreach Reporting Response to Treasury
14 July 2020 Private
In our view the draft still does not achieve the intended effect of the ASIC Enforcement Review recommendations in relation to the reporting of breaches and investigations, and requires some adjustments in other respects if it is to prove effective in improving the breach reporting regime.
Download PDFBanking Amendment (Deposits) Bill 2020
10 July 2020 Private
The ABA believes that deposits are currently protected and could not be bailed in during the resolution process of any ADI.
Download PDFPractical Compliance Guideline 2019/8DC1 – Transaction Accounts
10 July 2020 Private
In the end, we reluctantly agree with the position expressed at several points in the Summary of Responses, in that it will be up to individual ABA members to engage with the ATO on the application of the PCG to their particular factual circumstances. We note our disappointment with this as an outcome of a multi-year interaction between the ATO and the ABA as an industry association.
Download PDFATO Remediation Payment Data Request
2 July 2020 Private
The ABA requests that the ATO not issue notices requesting interest data in relation to remediation payments for the 2020 tax year. Any interest reporting should only commence once the remaining characterisation uncertainty is resolved and with clear reporting timeframes so that ABA members can establish appropriate systems and processes.
Download PDFApplication for ACCC Authorisation AA1000482
12 June 2020 Private
The ABA wishes to clarify, for the avoidance of doubt, that the ABA application seeks authorisation for three purposes: • deferring or varying loan facilities for customers in any sector of the economy or any customer segment impacted by COVID-19. • supporting Government initiatives to provide emergency fiscal stimulus and cost relief for individuals and businesses; or • ensuring continued high levels of customer service and access to banking services across the broadest possible range of times and locations.
Download PDFFinancial Institutions Supervisory Levies for 2020-21
12 June 2020 Private
The ABA is supportive of the legislative amendments on the basis that they will reduce cross-subsidisation between entities and more closely reflect the actual supervisory costs incurred by APRA. Without legislative amendment, the regulatory costs for smaller banks would continue to increase significantly. This may negatively impact competition and the increased costs would unnecessarily constrain the ability of some ADIs to continue lending to business and customers to support economic growth.
Download PDFAustralian Government’s response to the COVID-19 pandemic
10 June 2020 Private
Building upon the banking industry’s bushfire relief packages announced in January, the industry launched a comprehensive and swift response to the COVID-19 crisis. The response incorporates initiatives on loan deferrals and lending, banking accessibility, and electronic conveyancing and electronic mortgages.
Download PDFABA Response to Senate inquiry into Australian Government’s response to COVID-19
2 June 2020 Private
The response incorporates initiatives on loan deferrals and lending, banking accessibility, and electronic conveyancing and electronic mortgages. These measures were designed to support consumers and businesses through this difficult time and intended to mitigate the impacts of COVID-19 on bank customers.
Download PDFTreasury RIS consultation on Enhancements to Unfair Contract Term Provisions
27 May 2020 Private
The Australian Banking Association (ABA) supports an effective regulatory regime that provides consumers and small business with a strong level of protection from unfair contract terms (UCTs) in standard form contracts. In our view, making UCTs illegal and attaching penalties will result in a more legalistic approach to contracting and an adversarial process with regulators. We believe that a supervisory focused enforcement approach by regulators can best deliver improved outcomes for small business.
Download PDFLessons learned from the Australian bushfire season 2019-20
22 May 2020 Private
The ABA has set up a natural disasters work program that reports to our 16 Council members in order to clarify, strengthen and streamline the banking industry’s response to natural disasters to ensure that they have the right tools for the job at the right time. By the beginning of March 2020, the major banks had provided bushfire assistance grants totalling $7.6 million to more than 4,000 customers across Australia. The banks had also raised more than $42 million in donations to help devastated communities and assisted more than 3,500 customers with financial relief packages of the types described below.
Download PDFInquiry into Future Directions for the Consumer Data Right
21 May 2020 Private
The ABA supports the ongoing development and expansion of the Consumer Data Right (CDR). As the first sector to launch with Open Banking, the banking industry has contributed significantly to operationalising the CDR vision through expertise within the sector as well as providing the Open Banking systems through which the first consumer data will flow in the CDR.
Download PDFBCCC Vulnerability Inquiry
13 May 2020 Private
The focus of our submission goes to the timing for the inquiry. Given the intense demands on the resources of member banks due to the effects of the COVID-19 pandemic, and data requests to banks from other regulators on financial hardship, the ABA position is that the timeline proposed in the Consultation Paper should be revised.
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