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Read the calendar to stay up to date with upcoming ABA submissions.
240531 – APRA HPE consultation response
3 June 2024 Private
Feedback on APRA’s proposed HPE, compiled in consultation with ISDA
Download PDFPrudential Framework Minor Updates
6 May 2024 Private
Response to APRA consultation on changes to APS 330, APG 210 and treatment of General and Specific Provisions in APS 111, APS 220 and APS 330.
Download PDFSubmission on the Property Law Regulation 2024
28 March 2024 Private
The ABA strongly recommends the Queensland Government adopt mandatory disclosure of past flood and bushfire events in the proposed disclosure statement, and engage with State Governments, such as NSW and Victoria, where such disclosures are required, to overcome practical and legal challenges identified in the consultation paper on the Property Law Regulation 2024.
Download PDFABA Submission on BCBS Climate Disclosure Framework
28 March 2024 Private
The ABA and its members do not support the development of a separate Pillar 3 framework for climate-related risks. Instead, we believe that climate risks should be reported on through existing prudential categories such as credit risk or market risk.
Download PDFARS 117: Interest Rate Risk in the Banking Book
13 March 2024 Private
Submission on consultation for ARS 117.0 and ARS 117.1.
Download PDFRevisions to framework on Interest Rate Risk in the Banking Book
13 March 2024 Private
Submission in response to APRA consultation on changes to APS 117.
Download PDFADI Capital Reforms: Minor Updates
13 March 2024 Private
Submission in response to APRA’s consultation on minor updates to the capital framework announced in December 2023.
Download PDF231201 – Sustainable Finance Strategy – ABA Submission to the Treasury Consultation
4 March 2024 Private
ABA submission to the 2023 Treasury Sustainable Finance Strategy Consultation. This version of the upload fixes an issue in the PDF.
Download PDF240301 – Submission to AASB – ASRS Exposure Draft
4 March 2024 Private
ABA submission to the AASB consultation on Exposure Draft Sustainability Reporting Standards.
Download PDFTargeted changes to ADI liquidity and capital standards
20 February 2024 Private
Submission on proposed APRA targeted changes that would primarily affect ADIs on the Minimum Liquidity Holdings (MLH) regime.
Download PDF240209 – Climate-related financial disclosure – Treasury Exposure Draft Legislation
16 February 2024 Private
Notwithstanding our broad support for the regime, there are critical areas in the exposure draft that need to be addressed for the regime to operate successfully. Our submission makes recommendations in three key areas – the modified liability regime, consolidated reporting, and reporting location.
Download PDFWinding down Australia’s cheques system
13 February 2024 Private
ABA strongly supports the Government’s proposal to wind down Australia’s cheques system. The ABA also welcomes the Government’s engagement with the banking industry and the broader community on this plan.
Download PDFAmendments to the Electronic Conveyancing National Law
12 February 2024 Private
The ABA supports in principle the inclusion of compliance powers in the Electronic Conveyancing National Law (ECNL). However, the ABA considers it critical that the Australian Registrars National Electronic Conveyancing Council (ARNECC) is constituted with the appropriate understanding of the technical and operational details of interoperability, including financial settlement, to enforce its proposed new powers under the ECNL. It is fundamental that ARNECC or another appropriate body be equipped with the required expertise to oversee the compliance scheme beyond the scope of the registration and lodgement of title documents, and for the benefit of all participants in eConveyancing. Failure to do so has the potential to significantly impact on subscribers’ ability to confidently undertake eConveyancing transactions.
Download PDFReview of the Regional Investment Corporation 2018
12 February 2024 Private
The ABA acknowledges the intent of the RIC in supporting agribusinesses during periods of difficulty, such as natural disaster and drought. While the ABA acknowledges these additional loan categories may be valuable to eligible farmers, we note the RIC was first set up for the purpose of supporting drought affected farmers who may not have access to other financial lines. Comparatively, recent expansion of the RIC’s remit and the increase in the total loan amount offered has seen the RIC steadily shift towards an operational model as if it were a commercial finance provider, rather than a form of targeted government intervention in response to market failure. Through this lens, we consider the RIC should narrow its offering to prioritise activities and products that fill genuine market gaps or failures or in response to periods (such as during or in the lead up to periods of drought but not outside of these periods) that cannot otherwise be addressed by the commercial market. This will help to ensure that traditional providers of finance are not crowded out from the market or in competition with government, while targeting the RIC’s services towards farmers who need assistance in difficult circumstances of drought, disaster, or other adverse events (e.g. low commodity prices or import prohibitions imposed by foreign countries).
Download PDFSubmission – Payment System Modernisation Consultation Paper
9 February 2024 Private
ABA supports the Government introducing a licensing regime for payments service providers.
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