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 ABA thanks ASIC for the opportunity to comment on its discussion paper on the dynamics between public and private markets.
The ABA welcomes APRA providing clarity on the proposed targeted changes for Higher Education Loan Program (HELP) debt obligations and the constructive approach it is taking on this consultation.
The ABA welcomes APRA’s consultative approach to the potential impacts of the proposed replacement of AT1 capital with higher amounts of CET1 and Tier 2 capital under APRA’s prudential framwork in Australia.