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).
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The Australian Banking Association (ABA) welcomes the opportunity to provide this submission to the Senate Select Committee on Cost of Living’s (Committee) inquiry into the cost of living pressures facing Australians, ways to ease the cost of living and the Government’s fiscal policy response (Inquiry).
Banks are aware of the challenges Australians face in the current inflationary environment, which have arisen from a combination of the COVID-19 pandemic, high household savings, pent-up demand, and global factors, including supply chain constraints and the war in Ukraine. To curb inflation, the Reserve Bank of Australia (RBA), alongside other central banks globally, have responded by tightening monetary policy. The increases in the target cash rate have had flow-on effects to the cost of banking and living for Australian consumers.
The Australian Banking Association (ABA) welcomes the Treasury’s consultation and the role that this initiative can play in developing a crypto regulatory regime in Australia. Regulation of crypto assets The Reserve Bank’s retail Central Bank Digital Currency trial highlights the potential for crypto assets to benefit the economy, with a role for banks, payments, financial markets and fintechs. The crypto assets market continues to grow. An estimated 25.6% of Australians own crypto assets,1 and the global cryptocurrency market rebounded to an estimated US$1.08 trillion in early 2023.
The ABA supports the policy objective that large businesses pay small businesses on time. Banks have taken a range of steps to support small business customers throughout the COVID-19 pandemic and following recent major natural disasters. As a relatively new reporting regime, the ABA considers there is room to improve the scheme to ensure greater efficiency while maintaining or improving its effectiveness.