29 October 2020
The ABA does not support the proposed segmentation of banking data into high, medium, and low risk.
The speed at which the Australian Competition and Consumer Commission (ACCC) intends to finalise the draft Rules is concerning, especially given risks which have been raised in the Privacy Impact Assessment (PIA).
The ABA does not believe that it is possible for the ACCC to mitigate the risks raised in the PIA and concurrently resolve the questions and concerns raised in this submission by December 2020.
The ABA is particularly concerned with negative impacts the speed of implementation will have on smaller banks.
The ABA is also concerned that consumers may be overwhelmed with the level of complexity in the proposed Rules which may make them less likely to participate in the CDR. Trust in the security of the CDR is paramount to its success.
The ABA urges the ACCC to reconsider the intention to finalise these rules by December 2020 and seeks a meeting with the ACCC to discuss the concerns raised in this submission
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To assist consistency of implementation across the industry, the Australian Banking Association has developed industry position on a range of aspects regarding the implementation of APRA’s revised capital framework.
The ABA welcomes APRA’s ongoing engagement regarding the implementation of the revised APS 117 and provides the attached estimate of the associated compliance costs.
Australian banks are using new technologies to increase efficiency and to provide new and more responsive services to customers. We propose the government focus on: simplifying or rationalising existing legislation that impact on the use of AI and ADM, in preference to new specific AI regulations; any regulatory intervention including setting best practice guidance should build on existing best practices and harmonise with sector specific regulation; and review and amend legislation to be neutral as to whether a human or technology is used to make decisions or conduct a process.