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).
The ABA supports the introduction of mandatory climate-related financial disclosures aligned with the ISSB, and we feel that the proposed model generally strikes an appropriate balance. The submission makes key points across six areas: phased approach, reporting content, reporting location, assurance, continuous disclosure and the modified liability approach.
The ABA’s submission to the ACCC’s Retail Deposits Inquiry 2023. Australian banks continue to provide a competitive, dynamic, and innovative marketplace for deposits. Banks are also cognisant of the variety of uses for deposit accounts and strive to provide products and services that meet the needs of customers.