11 August 2021
The ABA provides the following recommendations and observations:
1. Promises to pay vs. financial hardship arrangements: We are concerned that ARCA’s proposal to define financial hardship arrangements (FHAs) is overly prescriptive and conflicts with elements of the National Consumer Credit Protection Act 2009 (NCCP).
2. Backdating the start of a financial hardship arrangement: The ABA does not support the approach allowing backdating of a financial hardship arrangement.
3. Payment test & catch-up periods: The ABA is supportive of the proposal for a payment test period or catch-up period to be treated as a financial hardship arrangement where the arrangement immediately follows, and is in response to, an earlier financial hardship arrangement.
4. Treatment of joint accounts where abuse is present: We are supportive of the interim proposal that ARCA has proposed to take extra care of customers experiencing family and domestic violence (FDV).
Latest articles
The ABA continues to support the intent of the CSLR as a last-resort scheme that compensates genuine victims where they have suffered actual financial loss as a result of financial misconduct that they have otherwise been unable to recover.
The Australian Banking Association (ABA) welcomes the opportunity to make a submission to the Treasury consultation Registry Stabilisation and Uplift – draft legislation (the consultation).
The Australian Banking Association welcomes the opportunity to comment on the Consultation Paper – 2026 Reforms to the AML/CTF Act.