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A sharing economy reporting regime – Consultation paper
22 February 2019 Private
The ABA does not support reporting by financial institutions (option 2) and agrees with the submission of the Australian Payments Network that such a reporting regime would not meet Treasury’s stated criteria of a good reporting regime.
Download PDFASIC Industry Funding Model and Registry Search Fees
8 February 2019 Private
The ABA supports the CCM initiative and its members are committed to co-operating with ASIC to ensure its success. The ABA supports the principle that costs of the close and continuous monitoring program should be contributed to by industry.
Download PDFResponse to Treasury: Privacy Impact Assessment – Consumer Data Right
18 January 2019 Private
It is important that the Consumer Data Right appropriately balances efficiency in the transfer of data and the risks to consumers’ privacy. The Privacy Impact Assessment (PIA) is an important step in achieving this balance.
Download PDFThe digital economy and Australia’s corporate tax system
13 December 2018 Private
Banks in Australia contribute a significant quantum of total corporate taxes paid in Australia and do not structure their tax affairs through low taxing jurisdictions. They were, therefore, not the obvious target of the recent OECD Base Erosion and Profit Shifting (BEPS) actions.
Download PDFCredit and financial services targeted at Australians at risk of financial hardship
14 November 2018 Private
All Australians should be afforded consistent consumer protection, no matter which credit or financial services provider they choose. For customers at risk of financial hardship, these consumer protections are particularly important.
Download PDFSubmission to the Royal Commission Interim Report
14 November 2018 Private
There are no excuses for the behaviour that has been exposed by the Royal Commission. We as Australia’s banks accept full responsibility for these failures and right now are working to make this right for customers who have been hurt. The ABA thanks all those customers who have come forward to give evidence along with Commissioner Hayne and his team for the comprehensive examination of the issues. It is clear throughout the report, and the hearings, that there were several themes of unacceptable behaviour. These include a focus on sales rather than service, poor culture and the way staff and third parties were paid.
Download PDFRegulations for Design and Distribution Obligations and Product Intervention Powers
13 November 2018 Private
These regulations would extend the operation of the Design and Distribution Obligations to additional financial products. This submission outlines the ABA’s concerns regarding some aspects of this proposal.
Download PDFInternational Capital Framework Comparability
12 November 2018 Private
While the ABA supports ‘unquestionably strong’ capital ratios, the ABA agrees with APRA that this embedded conservatism makes it more difficult and/or costly for Australian ADIs to access international capital markets if these Australian differences are not well understood, particularly during times of market dislocation.
Download PDFConsumer Data Right Industry Designation
23 October 2018 Private
The ABA believes that each industry would be better served by a designation tailored to their industry, rather than a broad instrument that is attempting to serve as a template.
Download PDFDesign and Distribution Obligations and Product Intervention Powers (Senate)
18 October 2018 Private
ABA members support the intent of the design and distribution obligations (DDO) to assist “consumers select appropriate financial products by requiring issuers and distributors to appropriately market and distribute financial products.”
Download PDFUpdated Consumer Data Right Exposure Draft
16 October 2018 Private
The ABA believes that having a well-designed reciprocity mechanism within the CDR is key to ensuring customers reap the full benefits of the data that is held regarding them.
Download PDFConsumer Data Right Rules Framework – ABA response to ACCC
12 October 2018 Private
ABA members believe that the CDR is a transformative reform and are committed to its success. The CDR has the potential to fuel innovation across the economy and benefit customers through an expanded choice of products and services.
Download PDFAPRA Discussion Paper: Revisions to the related entities framework for ADIs
4 October 2018 Private
The ABA is cognisant of the size and complexity of the task APRA has in finalising and calibrating a number of significant reforms to the Australian prudential framework. The ABA looks forward to continued dialogue to ensure an appropriate implementation of the capital framework for Australian ADIs.
Download PDFRoyal Commission Round 5 – Superannuation
21 September 2018 Private
In a market where many customers are disengaged and use a default fund, visiting a bank branch may be one of the few occasions where they can have their attention drawn to their superannuation.
Download PDFConsumer Data Right Exposure Draft Response
7 September 2018 Private
ABA members support the introduction of a consumer data right that will encourage innovation and enable customers to benefit from data sharing while ensuring their privacy is safeguarded. Appendix available here.
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