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 submissionDownload PDF
The Australian Banking Association (‘ABA’) welcomes the opportunity to make this submission to the Review of the Reserve Bank of Australia. The ABA notes the significant role of Australia’s central bank in delivering good economic outcomes for the nation. We support the ongoing independence of the Reserve Bank of Australia in executing its mandate.
The ABA’s responses to the panel’s questions in the Issues Paper (15 September 2022) raises these key points:
– We consider the three objectives to be appropriate, noting there may be an opportunity to update the expression of the objectives in Section 10(2) of the Reserve Bank Act (1959).
– We see opportunities for Reserve Bank of Australia (‘the RBA’ or ‘the Bank’) to augment its communications to explain the complexities underlying the decisions as well as greater explanation of the trade-offs made between the Bank’s objectives.
– We see the independence of the RBA as critical to ensuring a well-functioning economy.
Australian Banks support the intent of this global agreement to address the risks and leverage the opportunities arising from the digitalisation of the global and domestic economy. The ABA recommends that where possible, Australia’s implementation of the proposes measures should align with existing reporting and administrative requirements, and should be consistent with international approaches to ensure a streamlined and effective implementation.
The ABA considers the ASIC industry funding model is broadly meeting its objectives. The funding model promotes equitable outcomes across the financial services industry and for the community, by ensuring that entities that create the need for regulation bear the costs rather than taxpayers. However, there is scope to increase the transparency of the ASIC funding and improve some aspects of the reporting mechanisms.