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Read the calendar to stay up to date with upcoming ABA submissions.
APRA’s revisions to the capital framework for ADIs
23 September 2019 Private
An earlier implementation date for the revised operational risk capital requirements will be difficult and should be optional.
Download PDFFranchising Task Force Issues Paper – Response
20 September 2019 Private
The ABA is committed to supporting an effective and fair regulatory framework in the franchising sector. The ABA supports the need to have input from franchisees on franchising policy and is open to assisting the Taskforce to understand the benefits of existing governance mechanisms such as Franchise Advisory Councils
Download PDFTreasury Consultation on the Digital Platforms Inquiry 2019
19 September 2019 Private
The ABA acknowledges the breadth of the report and supports initiatives to improve privacy protections for banking customers. The ABA makes several points in this submission which warrant further review of recommendations 16-17 with respect to privacy, and also recommendations 20-21 with respect to unfair contract terms and unfair practices, and data portability.
Download PDFReview of the Intergovernmental Agreement for an Electronic Conveyancing National Law
19 September 2019 Private
The ABA welcomes the IGA review and is in general, supportive of its findings, draft recommendations and the draft options for improvement.
Download PDFFinancial institutions supervisory levy methodology discussion paper submission
13 September 2019 Private
The ABA supports appropriate cost reflective funding of APRA. An adequately resourced regulator will ensure its regulatory mandate is undertaken in a timely and effective way.
Download PDFThe Banking Executive Accountability Regime – Consultation on Product Responsibility
30 August 2019 Private
The ABA endorses recommendation 1.17 of the Financial Services Royal Commission and APRA’s core objective of heightened and clarified end to end accountability among senior executives for an ADI’s products.
Download PDFAPRA Consultations on margining and risk mitigation for non-centrally cleared derivatives
28 August 2019 Private
The ABA supports APRA’s amendments to Prudential Standard CPS 226 – margining and risk mitigation for non-centrally cleared derivatives (CPS 226).
Download PDFEconomy-wide Cash Payment Limit
12 August 2019 Private
The Australian Banking Association (ABA) supports the Government’s introduction of an economy-wide cash payment limit to businesses for goods and services. Having a taxation system that is robust and one that meets community expectations is vital and we recognise the importance of this initiative to the integrity of our tax system.
Download PDFConsultation Paper 313 – Product Intervention Power and draft Regulatory Guide
7 August 2019 Private
We acknowledge The Australian Securities and Investments Commission’s (ASIC) intention to provide ‘high level’ guidance, and to rely on the ordinary meaning of ‘significant detriment’. However, for the efficient implementation of this measure, maximum clarity around the meaning of this term is desirable.
Download PDFOpen Banking designation instrument consultation (2nd round)
11 July 2019 Private
Banking will be the first sector to apply the Consumer Data Right and the ABA supports the participation of more sectors over time to achieve an economy-wide open data regime.
Download PDFInteroperability between ELNOs (eConveyancing)
8 July 2019 Private
The ABA supports a national approach to eConveyancing and this includes a national regime for interoperability.
Download PDFAPRA consultation on APS 220 Credit Risk Management
5 July 2019 Private
The ABA welcomes the timely review of APS 220 to incorporate the new developments in credit risk management practices, including the new accounting standards and the Basel Committee supervisory guidance on sound credit risk practices. The ABA agrees that effective management of credit risk is a critical component of a comprehensive approach to risk management and essential to the long-term viability of any ADI. However, regulatory requirements should not create competitive impediments between ADIs and non-ADIs.
Download PDFComments on the Working Draft of the Consumer Data Standards
21 June 2019 Private
ABA’s submission to Data 61 on Consumer Data Rights Standards 0.9.3 highlighted the need for a number of important functional and security requirements to be embedded in the regime.
Download PDFConsultation on revisions to prudential practice guide APG 223 residential mortgage lending
21 June 2019 Private
The ABA welcomes APRA’s revision of the current buffer and floor limits set in December 2014.
Download PDFAddendum to Goods and Services Tax Ruling GSTR 2004/4DC1
31 May 2019 Private
The GSTR 2004/4DC1 should not be finalised in its current form, as it will lead to greater uncertainty in terms of industry participants self–assessing their input tax credit (ITCs) entitlements.
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