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Read the calendar to stay up to date with upcoming ABA submissions.
Consultation Paper – Electronic Creation and Execution of Documents
25 May 2023 Private
The ABA Submission is supportive of the Landgate’s efforts to enable the creation and execution of documents in electronic form. The ABA provides answers to the specific questions in the Landgate consultation paper.
Download PDFThin capitalisation submission to Treasury
27 April 2023 Private
The ABA Submission on the proposed changes to the Income Tax Assessment Act 1997, specifically the proposed changes to s25-90 and s230-15(3). The ABA’s position is that banks are unique in the application of the Thin Capitalisation rules and this uniqueness should be extended so banks continue to operate under s25-90 and s230-15(3).
Download PDFModernising Postal Services
27 April 2023 Private
ABA submission to Modernising Postal Services
Download PDFHEC Inquiry Economic Dynamism
20 April 2023 Private
Australian banks operate in a competitive and dynamic environment. They compete with each other and with other financial service providers, including tech companies, to provide products and services to consumers. Given the pace of technological change and transformation, banks are constantly innovating their customer offerings and processes to remain competitive. To compete effectively, banks continually adapt to respond to customer needs and preferences. As such, banks have, over the past several decades, become increasingly digital.
Download PDF2023-30 Australian Cyber Security Strategy Consultation
14 April 2023 Private
The ABA has responded to the Department of Home Affairs’ 2023-30 Australian Cyber Security Strategy Consultation. The ABA has provided several suggested improvements to Australia’s Cyber Security Strategy including consolidation of cyber and data security incident reporting requirements through a two-way ‘single door’ to ease the compliance burden on business, as well as the importance of a robust Digital ID framework. Further proposals raised include a safe harbouring mechanism for businesses impacted by cyber attacks to seek appropriate support, and a wider review of overlapping cyber security, privacy, and AML/CTF obligations should be undertaken with the objective of streamlining and consolidating the underlying compliance obligations.
Download PDFAUSTRAC Industry Contribution 2022-23 Stakeholder Consultation Paper
13 April 2023 Private
The ABA has responded to AUSTRAC’s annual consultation on its review of the Industry Contribution levy (the levy) paid by Reporting Entities to fund AUSTRAC’s operational expenditure. The ABA has reiterated comments called out from past submissions, while seeking transparency and further explanation from AUSTRAC on proposed changes to the levy in the consultation paper.
Download PDFData Standards Body (DSB) Decision Proposal – DP 288 – Non-Functional Requirements
6 April 2023 Private
The Data Standards Body (DSB) has issued a Decision Proposal (DP 288) on Non-Functional Requirements. These are technical reporting requirements required by the DSB to measure the performance of Open Banking Data Holders. These technical reporting requirements (Get Metrics) provide the regulator with information on performance of data sharing across multiple performance and data availability metrics. In this DP 288, the DSB has announced the creation of new Get Metrics and was seeking industry feedback.
Download PDFTreasury Laws Amendment (2023 Measures No. 1) Bill 2023 – Franked distributions funded by capital raisings
5 April 2023 Private
The ABA submission to the Senate Economic Committee, the submission addresses the importance of certainty regarding capital raises and distributions to banks.
Download PDFInquiry into bank closures in regional Australia
31 March 2023
ABA submission to the Senate Rural and Regional Affairs Committee inquiry into branch closures in regional Australia
Download PDFMergers & Acquisitions (M&As) Draft Guidance
30 March 2023 Private
The Australian Banking Association (ABA) has collaborated with its Members in an initial review of proposed amendments by AUSTRAC to industry guidance on Mergers and Acquisitions. AUSTRAC intends to conduct further consultation in the future on this guidance, and will notify the ABA, along with reporting entities of its intent, in due course.
Download PDFEnhanced Customer Due Diligence (ECDD) Revised Guidance
30 March 2023 Private
The Australian Banking Association (ABA) has collaborated with its Members in a further review (i.e., post-industry consultation), of AUSTRAC’s industry guidance on Enhanced Customer Due Diligence. AUSTRAC will be uploading a clean and final version of this guidance on its website soon. Equally, and before then, AUSTRAC may reach back out to the ABA for further questions, which may require additional engagement between the ABA and its Members.
Download PDFProposed Legislative Instrument LI 2022/D15
24 March 2023 Private
The ABA’s feedback on the revised draft Recipient Created Tax Invoices LI 2022/D15. The ABA proposes changes to the wording of the draft LI and suggests governance standards for periodic reviews of the registration status of suppliers.
Download PDFRationalisation of ending ASIC Instrument Measures
22 March 2023
The ABA supports the intent of simplifying obligations on entities by rationalising requirements into primary legislation or regulations. We also support initiatives that facilitate efficient development of digital only, or paper free, business relationships. We note that a majority of changes proposed for inclusion in the law or regulations mirror obligations from retiring Class Orders or legislative instruments. However, there are additional requirements in the draft regulations that appear to reduce flexibility and detract from broader reforms to ensure technology neutrality in business communications.
Download PDFConsultation on the Electronic Transactions Act
20 March 2023
The Australian Banking Association (ABA) welcomes the opportunity to respond to the Attorney-General’s Department’s consultation on the Electronic Transactions Act (ETA). ABA members support many aspects of electronic signing in Australia and note that significant changes are not required to the operation of the regime. The ABA highlights opportunities to refine the regime, particularly to drive more consistent approaches between State, Territory and Commonwealth regimes.
Download PDFOptions for an Australian SMS sender ID registry
14 March 2023 Private
The ABA supports the proposal of creating a SMS SenderID registry and believe it would be an extremely useful tool for protecting both business and customers. The ABA proposes adopting a registry with mandatory participation for businesses wishing to use an alphanumeric sender ID with the aim of addressing smishing and other SMS scams.
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