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Read the calendar to stay up to date with upcoming ABA submissions.
231013 – 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 PDF230831 – ABA feedback on 2023 Stress Test
1 September 2023 Private
ABA feedback on this year’s industry stress test
Download PDFDecennial Liability Insurance
31 August 2023 Private
The ABA broadly supports the proposal to introduce mandatory decennial likability insurance (DLI) in NSW from 2028, which aims to reduce the incidence of serious defects and support homeowners with rectification costs associated with defective building work. The ABA raises several matters for the Department’s consideration, including in relation to additional cost on housing, prescription of minimum requirements for DLI policies and concerns with the interim period between a developer’s engagement with a DLI insurer and issuance of a DLI policy.
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