Latest submissions

The Australian Banking Association provides submissions to Governments, regulators and other organisations about issues affecting the banking and financial services industry.

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Consumer Data Right Exposure Draft Response
7 Sep 2018
ABA members support the introduction of a consumer data right that will encourage innovation and enable customers to benefit from data sharing while ensuring their privacy is safeguarded. Appendix available here.
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Product Intervention and Design and Distribution Obligations
15 Aug 2018
The banking industry supports the intent of the Design and Distribution Obligation (DDO) to assist “consumers select appropriate financial products by requiring issuers and distributors to appropriately market and distribute financial products,” but highlights some concerns around the current draft legislation.
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ABA Response to Australian Financial Complaints Authority rules consultation
6 Jul 2018
The ABA appreciates the opportunity to comment on the proposed AFCA rules and expresses our view that its operation should be efficient and effective and that decision processes should be transparent and clear as this is in the best interest of customers.
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Introducing an economy-wide cash payment limit
5 Jul 2018
The ABA supports the Government’s announcement of an economy-wide cash payment limit of $10,000 for payments to businesses for goods and services, to apply from 1 July 2019. However we raise four points around the operation of the $10,000 limit to ensure it meets the Government’s intentions and does not lead to any unintended consequences or unnecessary red tape.
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Revisions to the minimum capital requirements for market risk
20 Jun 2018
This consultation is a step forward in improving the risk sensitivity, consistency and operational process of some aspects of the market risk framework. However, certain aspects of the framework remain excessively onerous, unduly complex and unrepresentative of the actual risk intended to be mitigated in smaller markets such as Australia.
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Revisions to the capital framework for ADIs
15 Jun 2018
The ABA welcomes the APRA discussion paper which includes proposed revisions to the capital framework, as well as other changes to better align the framework to risks, including in relation to housing lending.
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Information security management: A new cross-industry prudential standard
7 Jun 2018
The ABA welcomes APRA’s steps to strengthen the industry’s cyber resilience and also supports measures that will require all regulated entities to lift their cyber security capabilities.
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Leverage ratio requirement for ADIs
1 May 2018
The Australian Banking Association (ABA) appreciates the opportunity to provide APRA with comments on the Discussion Paper: Leverage ratio requirement for authorised deposit-taking institutions
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BEAR Regime - Size of an ADI - Draft Legislative Instrument
20 Apr 2018
The ABA recommends that the draft legislative instrument be amended so that a ‘small ADI’ would be defined as having less than or equal to $30 billion total resident assets rather than the current definition of having less than or equal to $10 billion total resident assets (on a three-year average).
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Competition in the Australian Financial System
29 Mar 2018
Australian banks will continue to support evidence-based regulatory change that encourages competition and innovation while ensuring stability through the economic cycle. ABA members support many of the draft recommendations in the Productivity Commission’s draft report into Competition in the Australian Financial System.

What’s new

A sensible path forward for Open Banking
10 May 2018
Open Banking will allow customers, at their request, to share their personal information with other financial institutions to allow them to find a better deal on expenses such as electricity bills, telecommunications and other items.
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ABA blog

Customers at centre of mortgage industry overhaul
Christine Cupitt, Executive Director - Policy, Australian Banking Association
Read more 1 Feb 2018

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