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Review 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.
Download PDF231213 – Shaping the Future of Climate Active
5 February 2024 Private
Climate Active fills an important role by providing tools and guidance for entities commencing their decarbonisation journey. We note the relationship between Proposal 3, which seeks feedback on mandating specific indirect (Scope 3) emissions sources, and Proposal 8, which would require 100% of emissions to be offset for an organisation to qualify for Certified-stage requirements. Creating a requirement or expectation that banks offset Scope 3 financed emissions would add extraordinary and impractical costs and create duplication of offsetting across industries. This could potentially create new costs for customers or, more likely, result in banks withdrawing from the scheme.
Download PDFAmendments of the Payment Systems (Regulation) Act 1998
1 February 2024 Private
ABA strongly supports the intent of the legislation to modernise the payments regulatory framework to ensure that it is fit-for-purpose and can address emerging risks related to payments.
Download PDFSenate Economics Committee Inquiry – Digital ID Bills
1 February 2024 Private
The Australian Banking Association (ABA) has long advocated for the broad adoption of Digital ID services in Australia as an essential element of the evolving digital economy.
Download PDFScams – Mandatory Industry Codes
1 February 2024 Private
The overarching success measure for the proposed Framework will be whether it improves scams prevention and disruption across the ecosystem of sectors and law enforcement, and creates more accessible and consistent outcomes for consumers.
Download PDFQuality of Advice Review – Delivering Better Financial Outcomes Tranche 1 – reducing red tape and other measures
30 January 2024 Private
ABA submission to Quality of Advice Review – Delivering Better Financial Outcomes Tranche 1 – reducing red tape and other measures
Download PDFASIC Consultation Paper 373 – proposed changes to the Banking Code of Practice
30 January 2024 Private
ABA submission to ASIC Consultation Paper 373 – proposed changes to the Banking Code of Practice
Download PDFUnfair Trading Practices Submission
30 January 2024 Private
ABA submission to Unfair Trading Practices Consultation
Download PDFPersonal Properties Securities Act (PPSA) Reform
30 January 2024 Private
ABA’s submission to the PPSA Reform Consultation
Download PDFABA-LUV – Changes to Registrar’s Requirements
28 November 2023 Private
The ABA has concerns with the proposed Registrar’s Requirements and their impact on the Memorandum of Common Provisions (MCPs). We respectfully request that LUV reconsider the adoption of the proposed Registrar’s Requirement 19. This change phases out of the use of already registered and long-established MCPs across industry, with little policy justification. The ABA maintains committed to a nationally consistent approach to conveyancing and the adoption of best and consistent practice, wherever possible. The ABA notes the rationale for the proposed change is unclear and considers the change will result in national inconsistency and bespoke processes for MCPs in Victoria.
Download PDF231106 – ABA Submission on changes to EFS
10 November 2023 Private
This is the ABA submission on the proposed changes to modernised Economic and Financial Statistics reporting standards and guidance.
Download PDFHousing Australia Investment Mandate Direction
9 November 2023 Private
The ABA continues to support establishment of the Housing Australia Future Fund as a mechanism to provide a sustainable funding source to support and increase the development of social and affordable housing during a critical period of lower than required housing supply. The ABA acknowledges that other industry factors such as planning, and the cost and availability of appropriate construction services, will also be important in stimulating housing supply. The ABA seeks Housing Australia to continue to undertake close consultation with, and work alongside, banks and the private sector to ensure it supports the crowding in of financiers.
Download PDFARNECC draft 7.2 Model Operating Requirements
6 November 2023 Private
The ABA acknowledges the work of ARNECC to date in developing the interoperability program. We continue to support the intention of interoperability on the basis that eConveyancing transactions under interoperability are substantively like those under a non-interoperable framework. However, the ABA has significant concerns that the interoperability program will be impacted by the failure to resolve issues relating to the scope, functionality, innovation and payment and settlement flows of the program. The ABA makes five key recommendations to ARNECC. While these comments will not address the extent of banks’ concerns with the interoperability program, their resolution will demonstrate ARNECC’s commitment to the delivery of interoperability for all users, including subscribers and customers.
Download PDFScreen Scraping
31 October 2023 Private
The ABA broadly endorses the recommendation from the CDR Statutory Review that screen scraping be banned where the CDR is a viable alternative. To make the CDR a viable alternative, it needs to offer a comparable customer experience to screen scraping. To date, many of the previously implemented and currently proposed changes to the CDR have not moved the CDR closer towards this goal. The ABA recommends pausing any changes to the CDR that are directed towards meeting this goal.
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