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ABA submission – AFCA Responsible Lending Approach
31 October 2023 Private
A submission to AFCA providing feedback on its draft approach to Responsible Lending complaints.
Download PDFAppropriate Lending Approach to Small Business
16 October 2023 Private
The provision of credit to small business is critical to the success of the economy and the prosperity of Australians, and ABA members are committed to the success of Australia’s small business sector. The ABA acknowledges AFCA’s work in developing a public approach to small business lending and understands that AFCA’s intention in publishing its approach to small business is to aid small business borrowers and lenders in understanding how AFCA currently approaches its determinations. However, there is a likelihood that the degree of prescription AFCA adopts in the draft SME Approach may have this effect and introduce a level of detail that goes beyond existing requirements under laws, standards, and codes. We urge AFCA to adopt a principles-based approach based on established principles, standards, and requirements in small business lending, such as the BCOP, to ensure that lending to small businesses is not restricted and is consistent with existing requirements.
Download PDF231013 – ABA Submission on CPG 230
13 October 2023 Private
This is the submission in response to APRA’s consultation on Draft CPG 230 Operational Risk Management.
Download PDFFranchising Review
4 October 2023 Private
ABA members are committed to the success of Australia’s franchisors and franchisees, who play an important role in our economy. The ABA supports retention of the Franchising Code of Conduct and the Franchise Disclosure Register and acknowledges the important role these tools have in protecting both franchisors and franchisees, which are often small businesses. Entering a franchising arrangement is a significant legal and financial undertaking and it is sometimes the case that individuals who are attracted to franchising are also newer to business. Franchisees should be encouraged to undertake due diligence to ensure they are well informed about the risks and responsibilities, as well as their rights, prior to entering into their chosen franchising agreement.
Download PDFPersonal Insolvency Discussion Paper
3 October 2023 Private
ABA’s response to Attorney General Department Personal Insolvency discussion paper
Download PDFPersonal Insolvency Discussion Paper
3 October 2023
Response to Discussion Paper released by AGD
Download PDF230922 – ABA Submission on Amendments to Capital Adequacy Reporting Standards ARS 180
27 September 2023 Private
This is a letter to APRA on their proposed changes to ARS 180 urging greater consideration of proportionate regulation.
Download PDF230831 – ISSB Consultation on agenda priorities
18 September 2023 Private
ABA submission to the ISSB Consultation on Agenda Priorities.
Download PDFABA letter – APS 115 Treatment of Subsidiary Dividends
11 September 2023 Private
This is a letter to APRA on whether dividend income from non-consolidated subsidiaries, associates and joint ventures should be included as income when calculating under APS 115.
Download PDFMiscellaneous Amendments to Treasury Portfolio Laws 2023
6 September 2023 Private
ABA’s submission on proposed changes to Input Tax Credits
Download PDFABA letter to APRA – Multilateral LGD
6 September 2023 Private
ABA addressing APRA’s LGD treatment of Multilateral Banks
Download PDFABA letter on 5+ properties
6 September 2023 Private
ABA addresses member concerns regarding APRA’s treatment of 5+ properties
Download PDF– ABA letter to APRA on proposed changes to the capital framework
6 September 2023 Private
ABA addressed the following: 1. Credit Worthiness Checks for Commitments 2. Recognition of carbon credits as eligible collateral 3. Entities eligible for the 25% Infrastructure LGD
Download PDFALRC Interim Report C Submission
4 September 2023 Private
Submission to ALRC Interim Report C
Download PDFAPRA consultation on with IRB banks’ response to the changes to the capital framework
1 September 2023 Private
IRB banks response to APRA’s bilateral consultation on proposed changes to the Capital Framework
Download PDF