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Read the calendar to stay up to date with upcoming ABA submissions.
Consultation on responsible lending (RG209)
20 May 2019 Private
The ABA is concerned that a move away from a principles-based approach will negatively affect competition.
Download PDFAustralian Law Reform Commission Corporate Crime Inquiry
17 May 2019 Private
It is important that any consideration of the liability of individuals for corporate misconduct take account of the various avenues pursuant to which individuals might be personally liable for corporate misconduct under the law as it stands.
Download PDFPrudential Practice Guide CPG 234 Information Security
17 May 2019 Private
The ABA has specific comments on the following chapters: Third parties and related parties Implementation of controls Internal audit Attachment B: Training and awareness Attachment C: Identity and access
Download PDFACCC Draft Consumer Data Rules
10 May 2019 Private
The ACCC’s draft Rules provide a good foundation for the implementation of open banking, however there are a number of areas that have not been addressed in the draft Rules or which require further guidance.
Download PDFEnforceability of financial services industry codes
18 April 2019 Private
Recommendation 1.15 should be implemented in a manner consistent with Commissioner Hayne’s clear intention to preserve the benefits and fundamental self-regulatory characteristics of financial sector codes.
Download PDFAFCA Rules Consultation – Legacy Disputes
15 April 2019 Private
This is an important first step in enabling AFCA to deal with legacy complaints about conduct by financial firms dating back to 1 January 2008 that have not been previously considered and fall outside the period allowed under AFCA’s existing jurisdiction.
Download PDFAPRA Capability Review
12 April 2019 Private
The ABA supports the Government decision to undertake regular capability reviews of financial regulators as recommended in the Royal Commission Final Report.
Download PDFIGA eConveyancing Paper
10 April 2019 Private
While the Issues Paper comprehensively considers the impact of eConveyancing from an industry and government perspective, greater consideration should be given to the consumer outcome.
Download PDFBanking System Reform (Separation of Banks) Bill 2019
9 April 2019 Private
The ABA does not support this Bill and has concerns with the drastic regulatory intervention it proposes. The industry’s existing reform program will be more efficient, less costly and less disruptive to the economy and community.
Download PDFConsumer Data Right – Energy Sector
22 March 2019 Private
Banking will be the first sector to apply the CDR and the ABA supports the participation of more sectors over time to achieve an economy-wide open data regime.
Download PDFEnding Grandfathered Conflicted Remuneration for Financial Advisers
22 March 2019 Private
While our member banks have taken steps to remove these conflicts of interest, the industry has advocated for a legislative approach to implementation of these reforms to ensure consistency across the industry and overcome practical and contractual challenges to fully removing conflicted remuneration.
Download PDFCoordination and funding of financial counselling
21 March 2019 Private
There is significant unmet demand for financial counsellors and the banking industry supports additional funding to meet this need.
Download PDFResolution of disputes with financial service providers within the justice system
5 March 2019 Private
ABA member banks have committed to and are taking significant steps to change their processes and culture to ensure there is no repeat of the cases heard at the Royal Commission.
Download PDF2019 Australian Payments Plan Consultation
1 March 2019 Private
The people who currently use cash most heavily, or are least digitally-active, are often those in potentially vulnerable circumstances, including consumers living in remote communities and the elderly.
Download PDFConsumer Data Right Bill Inquiry
28 February 2019 Private
The Privacy Safeguards should be aligned with the Australian Privacy Principles where possible, particularly in relation to Privacy Safeguard 4.
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