- 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.
Financial Regulator Coordination and Information Sharing
24 January 2020 Private
The ABA supports the codification of the expectation that where one regulator possesses information about an obvious and significant breach of laws administered by the other, the regulator should pass that information on. This will ensure early detection of misconduct and swifter enforcement action.
Download PDFOAIC Public Interest Determinations on International Money Transfers
24 January 2020 Private
The applications seek new PIDs to permit ANZ – along with other authorised-deposit taking institutionswithin the meaning of the Banking Act 1959 (ADIs); and the RBA to disclose the personal information ofa beneficiary of an IMT to an overseas financial institution when processing an IMT, without breachingthe Australian Privacy Principles (APPs). The ABA strongly supports these two applications and urges the OAIC to issue new PIDs which would replace existing PIDs concerning IMTs that are due to sunset on 25 February 2020
Download PDFResponse to the Select Committee on FinTech and RegTech
24 December 2019 Private
The ABA agrees that capital and funding, tax, skills and talent, culture and regulation are key factors that determine Australia’s competitive position to attract and maintain investment in technology. However, the ABA respectfully requests to also consider how Australia should best manage data in the emerging digital economy.
Download PDFInterest rate risk in the banking book
16 December 2019 Private
The ABA supports the alignment of APS 117 with the Basel Committee on Banking Supervision interest rate risk in the banking book issued April 2016 where appropriate.
Download PDFDraft Consumer Data Right Privacy Safeguard Guidelines Consultation
27 November 2019 Private
The ABA recommends that the PS GL undergo a second consultation twelve months after the launch of the CDR regime, and the ABA recommends that the OAIC institutes a process for annual review.
Download PDFUpdate to RG 209 Credit Licensing: Responsible lending conduct
26 November 2019 Private
The ABA supports ASIC finalising this review and releasing updated regulatory guidance as soon as possible to provide clarity and assist credit licensees comply with their responsible lending obligations.
Download PDFSupplementary submission to ASIC Consultation Paper 209: Update to RG 209 Credit Licensing: Responsible lending conduct
26 November 2019 Private
The ABA strongly supports the retention of a principles-based approach to responsible lending through the legislative provisions contained in the NCCP Act, as well as in relation to relevant regulatory guidance, including in ASIC’s RG 209 and APRA’s APG 223 and APS 220.
Download PDFAPRA Consultation on CPS 511 Remuneration
19 November 2019 Private
The issue being addressed under CPS 511is that remuneration structures of key staff need to be betteraligned with the risk-generating potential of activities of thosestaffto the organisation. In seeking to bring about a better alignment, draft CPS511 adopts a prescriptiveapproach.The ABA believes that a prescriptive approach is problematic.
Download PDFCapital treatment of mortgages under the First Home Loan Deposit Scheme
11 November 2019 Private
The ABA welcomes further clarity on the capital treatment for guarantees under the Scheme. A clear understanding of the capital treatment is critical for an ADI’s mortgage product development and consequential approval under the scheme.
Download PDFNational Housing Finance and Investment Corporation Investment Mandate Amendment (First Home Loan Deposit Scheme) Direction 2019
4 November 2019 Private
The ABA welcomes any assistance to help first homebuyers to own their own home and supports the Government’s commitment to deliver the First Home Loan Deposit Scheme. Further, the ABA welcomes APRA’s letter to industry clarifying the capital treatment of the guarantee.
Download PDFTreasury consultation on Open Banking Privacy Impact Assessment (PIA)
28 October 2019 Private
The ABA views any changes to the Consumer Data Right (CDR) regime as likely to have a significant impact on the privacy of individuals, thereby warranting reconsideration of the risks and recommendations made by the PIA. This review process is crucial to ensuring that the CDR regime will meet its stated goal of being ‘consumer focussed’.
Download PDFRemoval of the exemption for funeral expenses policies
18 October 2019 Private
The ABA fully supports the removal of the exemption for funeral expenses policies from the definition of financial products.
Download PDFCorporations Amendment (Design and Distribution Obligations) Regulations 2019
11 October 2019 Private
The ABA welcomes the exclusion from the requirement to provide a Target Market Determination (TMD) of credit provided wholly or predominantly for business purposes. In implementing this legislation, it is important that the principle of scalability be flexibly applied and that clear guidance be given on this by ASIC. We welcome the clarification around the… Read more »
Download PDFASIC Enforcement Review Taskforce
11 October 2019 Private
The ABA supports stronger powers for ASIC and a strengthening of the regulatory framework for financial services and corporations laws generally as recommended by the ASICERT.
Download PDFReview of the pricing framework for electronic conveyancing services in NSW
1 October 2019 Private
The most important issue for the ABA is that Australia adopts a nationally consistent approach to eConveyancing as it will drive competition, choice and price efficiency.
Download PDF