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APRA Consultation on APS910 – ABA submission
31 August 2023 Private
APS 910 Financial Claims Scheme (APS910) is due to sunset on 1 October 2023 and the Australian Prudential Regulation Authority (APRA) is consulting on the proposal to remake it with minor amendments. The ABA supports the remaking of APS910 with the proposed minor amendments, these are noted in the Submission.
Download PDF230823 – Submission – APRA Consultation on APS 910
31 August 2023 Private
The ABA supports the remaking of APS910 with the proposed minor amendments.
Download PDF230808 – Submission – FRAA Draft Regulator Metrics
31 August 2023 Private
Our submission makes the following overall points: – Metrics. We note that the metrics most likely to be of use to the FRAA are those which are closely related to the statutory objects and powers of the Australian Securities and Investments Commission (ASIC) and the Australian Prudential Regulation Authority (APRA). Our view is that metrics related to broader macro-economic or financial system performance are less likely to be useful, as they would require significant interpretation to draw actionable conclusions and would draw the FRAA into the position of making normative judgments. – Characteristics and outcomes. While noting the FRAA’s intention to develop a more holistic understanding of the quality of financial system regulation, we do not view that the outcomes supporting the FSI characteristics are an exact match against the statutory powers and objects of APRA and ASIC. Our view is that a set of outcomes more directly aligned to those statutory powers and objects will provide a better understanding of their performance. – Alternative metrics. Finally, our submission proposes some alternative metrics to help capture the strategic performance of the regulators.
Download PDFRBA Retail Payments Statistics Review
31 August 2023 Private
The ABA is generally supportive of the RBA’s proposed revised approach to retail payments statistics. However members have requested an adequate period to facilitate this transition, and also asks the RBA to consider collecting contactless/contact data from card schemes.
Download PDF230801 – Submission – Modernising Document Execution
31 August 2023 Private
This submission makes the following three key points: – As in the 2021 inquiry, the ABA supports the proposal to allow consumers and businesses to make statutory declarations electronically. We view this as an important step in realising the benefits of a digital economy and making the benefits of modern business communications consistent and sustainable. – There is merit in a nationally consistent approach to allowing digital ID to be used to other documents whose execution is governed by Commonwealth, State or Territory law. Inconsistencies between Commonwealth, State and Territory legislation regarding document execution can offset some of the benefit of these reforms. – We support the proposed integration with the Australian Government Digital Identity Service (AGDIS), conditional on allowing Australians to use a range of Digital Identity Providers (ie. beyond myGov and myGovID) within the AGDIS ecosystem to execute statutory declarations. We suggest further consultation on the process flow and technical requirements at an appropriate time.
Download PDF230817 – Financial Accountability Regime – Regulator Rules Consultation
31 August 2023 Private
Our submission makes the following three key points: The ABA recommends the release of a single guidance note or information paper, which would consolidate the Regulator Rules, Transitional Rules, Key Functions Document, and any relevant additional information contained in the Consultation Letter. Accountability statements are intended to articulate the scope of accountability for APs of ADIs in a way that satisfies the requirements in the legislation. It is unnecessarily duplicative and administratively burdensome to add to this obligation by also requiring entities to include Key Function prescribed information in the register. Further clarification is required in relation to the types of changes that will constitute a “material” change for purposes of the FAR (thereby triggering the notification obligation).
Download PDF230630 – Setting, tracking and achieving Australia’s climate targets
25 August 2023 Private
This submission highlights the significance of data availability towards tracking and achieving Australia’s emissions reduction targets. Broadly speaking, data availability is globally recognised as a key enabler of emissions reduction. The Treasury consultation Climate-related financial disclosure (ongoing at time of writing) recognises these data challenges and has noted that the Government’s forthcoming Sustainable Finance Strategy will address this issue in more detail. Finally, the Climate Vulnerability Assessment found that climate-related data quality and accessibility remain a challenge.
Download PDF230724 – Climate-related financial disclosures – second-round consultation – ADDENDUM
25 August 2023 Private
Short addendum to the submission of 21 July.
Download PDF230721 – Climate-related financial disclosures – second-round consultation
25 August 2023 Private
The ABA has long supported the introduction of mandatory climate-related financial disclosures aligned with the International Sustainability Standards Board (ISSB), and we feel that the proposed model generally strikes an appropriate balance. We understand that many of the specifics of implementation will be subject to further consultations, including by the Australian Accounting Standards Board (AASB) and the Government’s own forthcoming Sustainable Finance Strategy consultation. While we look forward to making further comments under those processes, we wish to reiterate that effective and efficient implementation will depend on support via national data assets and methodological support.
Download PDF230217 – Climate-related financial disclosures – first-round consultation
25 August 2023 Private
The ABA supports the introduction of mandatory climate-related financial disclosures aligned with the International Sustainability Standards Board (ISSB). This will provide banks and business with the certainty they need to manage their climate risks and to grasp the opportunities from the new green industrial revolution.
Download PDF221215 – Empowering the AASB to deliver sustainability standards
25 August 2023 Private
The ABA supports the draft legislation to the extent that it allows the alignment of Australian accounting standards with global standards, namely the IFRS S1 General Requirements for Disclosure of Sustainability-related Financial Information (IFRS S1) and the IFRS S2 Climate-related Disclosures (IFRS S2). The ABA views that further consideration is needed to identify appropriate long-term governance arrangements, and we intend to make further comments on this matter in our submission to the Treasury consultation on Climate-Related Financial Disclosures.
Download PDF230303 – Nature Market Repair Bill – Exposure Draft
25 August 2023 Private
Australian banks are generally supportive of nature-related markets, payments for ecosystem services and providing incentives to landholders to create positive outcomes for nature. We support a well-designed, outcomes-based market that connects non-government finance with landholders and facilitates banks in Australia financing biodiversity projects. The ABA views that, properly implemented, there will be merit in many elements of the proposal, including the standard-form biodiversity certificate, auditing measures and measures for capturing and measuring improvements in biodiversity. We welcome the establishment of the Nature Repair Market Committee, to be comprised of expert advisers across the six listed fields, which will support advanced knowledge of biodiversity attributes.
Download PDFSafe and responsible use of AI
15 August 2023 Private
ABA advocates for a considered and efficient approach by Government to AI. Banks have a history of using technology to improve customer service and enhance the security of banking. Our understanding of the potential uses of AI and the impact of some uses, and what may be fit for purpose, governance of the development and use of AI, is evolving.
Download PDFThe Australian Debit Card Market: Default Settings and Tokenisation
2 August 2023 Private
ABA supports the policy objective of helping merchants, including small businesses, to manage the cost of payments acceptance, while balancing merchants’ need for transparency, simplicity and cost effectiveness and considerations for consumers’ user experience.
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