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ASFI Progress Report
11 May 2020 Private
The ABA recommends sequencing the challenges into ‘lead’ priorities and ‘consequential’ priorities. Imminent challenges should be a first order of priority. Although the challenges highlighted in the report are interlinked, the agenda envisaged by the Report is expansive and will prove challenging to scope and implement. Throughout the process, it will be important to align and integrate with existing frameworks, tools, and standards and therefore to avoid duplication of work and effort. The regulatory requirements for climate risk management and the aligning of disclosures to the TCFD framework will be a priority for the banking sector in 2021.
Download PDFAusPayNet application for revocation of authorisation A91497 and A91498 and substitution of AA1000495
6 May 2020 Private
The ABA supports the AusPayNet application for re-authorisation. The ABA considers the Issuers and Acquirers Community (IAC) framework provides opportunities for coordination, self-regulation and policy setting which delivers important public benefits.
Download PDFLetter to BCCC – Issuance of Scheme and Dual Network Debit Cards
28 April 2020 Private
The Australian Banking Association (ABA) wishes to notify the Australian Financial Complaints Authority (AFCA) that a group of our member banks have developed and intend to implement an initiative involving the issuance of scheme or dual network debit cards to assist bank customers impacted by COVID-19.
Download PDFLetter to BCCC – Issuance of Scheme and Dual Network Debit Cards
28 April 2020 Private
The Australian Banking Association (ABA) wishes to notify the Banking Code Compliance Committee (BCCC) of the approval of our recent application to the Australian Securities and Investments Commission (ASIC) for relief from provisions of the Corporations Act 2001 (Corporations Act) and the Australian Securities and Investments Commission Act 2001 (ASIC Act) to allow for the proactive issuance of scheme and dual network debit cards to bank customers.
Download PDFNotification of Debit Card Program
18 April 2020 Private
The Australian Banking Association (ABA) notifies the ACCC under the interim authorisation (number AA1000482) granted to the ABA and its member banks on 30 March 2020, of a decision by certain member banks to implement a program to fast track the issuing of scheme or dual network debit cards to isolated and vulnerable customers in the Australian community for purpose of ensuring accessibility to banking services.
Download PDFNew policy application for relief – issuance of scheme or dual network debit cards
10 April 2020 Private
In light of the COVID-19 implications of business closures, decline in the acceptance of cash by retailers and the stricter rules imposed by the Federal Government with regards to self-isolation, we believe that this may have serious adverse impacts on these customers who will be unable to make necessary payments for their goods and services either in person or through online shopping. To ensure accessibility, we are seeking relief from ASIC to be able to fast track the issuance of scheme or dual network debit cards to these customers.
Download PDFFully Electronic Mortgages
9 April 2020 Private
The advent of electronic lodgement networks which facilitate financial settlements of land dealings in a number of jurisdictions has for the first time raised the possibility of taking real property mortgages in a ‘fully electronic way’. However, there are still impediments: (a) each State that facilitates online lodging of mortgages, has approached the legal and practical response to the requirements for fully electronic mortgages in different ways (and, in some instances, interpreted similar concepts in different ways); and (b) each State has left some gaps in its legal and practical response which cause concern for financiers who rely on certainty of enforceability.
Download PDFAuthorisation Application to Implement Small Business Relief Package
30 March 2020 Private
The ABA, on behalf its Member Banks, is now seeking authorisation from the ACCC, to discuss, agree, and give effect to any arrangement between Member Banks that has the purpose of deferring or varying loan facilities for customers, supporting Government initiatives to provide emergency relief for individuals and businesses, or ensuring continued high levels of customer service and accessibility, for a period of 12 months from the grant of final authorisation.
Download PDFAPG 220 Credit Risk Management Submission
19 March 2020 Private
The ABA is supportive of modernising prudential guidance in line with contemporary credit risk management practices. However, it is important to ensure that any new guidance sits comfortably within a predictable and transparent regulatory framework for ADIs
Download PDFProduct Design and Distribution Obligations – ASIC CP 325 Draft Guide
18 March 2020 Private
The draft Guide released by ASIC is a good beginning. If it is to achieve its optimal effect, however, we believe that it could be improved in several respects. The regime is complex and implementing it imposes a significant burden on industry.
Download PDFEnduring Power of Attorney – Mandatory National Register
15 March 2020 Private
The ABA supports the introduction of a mandatory register of Enduring Power of Attorney (EPOA) and General Power of Attorney (GPOA) instruments. The introduction of a mandatory national register will greatly assist in safeguarding older and vulnerable people by providing a reliable single source of information to verify the authenticity and currency of an instrument.
Download PDFProposed timetable for participation of non-major ADIs in the CDR
3 March 2020 Private
In discussions between the ACCC, ABA and non-major banks on 13 February 2020, the ABA and members unanimously expressed their concern for the 1 February 2021 launch for phase 1 products. Members reconfirmed the importance for maintaining a 12-month implementation timeline from the major banks’ launch date.
Download PDFModel Participation Rules – ARNECC Consultation Draft Version 6
2 March 2020 Private
The proposed amendments to the MPR are significant and the ABA is strongly opposed to Draft Version 6 of the MPR in their current form. The ABA is not aware of any instance of identity fraud in the electronic e-conveyancing system that would warrant such significant and costly changes.
Download PDFARNECC Model Participation Rules
2 March 2020 Private
The proposed amendments to the MPR are significant and the ABA is strongly opposed to Draft Version 6 of the MPR in their current form. ARNECC has not provided reasoning, analysis or a business case to justify the need for such significant changes. ARNECC has not explained the problems or risks that the changes seek to address or mitigate. The ABA is not aware of any instance of identity fraud in the electronic econveyancing system that would warrant such significant and costly changes.
Download PDFASIC Directions Power
28 February 2020 Private
The ABA supports the introduction of the new ASIC directions power, however clear expectations and important changes are needed to give industry confidence and clarity about how and when it will be used. General powers such as the directions power should not be used to undermine limits on specific powers.
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