18 August 2021
In the ABA’s view, the guidance detailed throughout RG38 provides clarity over the forms of communication subject to the prohibition, the nature and scope of a consumer’s consent. However, the guide does not adequately consider the types of interactions between customers and frontline staff. These interactions vary greatly and, in many cases, involve a frontline staff member needing to gain an understanding of a customer’s needs to educate them on the scope of products.
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The Committee should recommend a policy and regulatory framework that manages risk and maximises opportunity, giving businesses the confidence to invest, innovate and deploy AI at scale for the benefit of customers, while preserving Australia’s capacity to use AI to protect and advance the national interest.
The Australian Banking Association (the ABA) welcomes the opportunity to comment on the Consultation Paper that will inform the direction and development of the Second Action Plan under Australia’s National Plan to End Violence against Women and Children 2022-2032 (the National Plan).
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.