APG 220 Credit Risk Management Submission

The ABA supports the ongoing development and expansion of the Consumer Data Right (CDR). As the first sector to launch with Open Banking, the banking industry has contributed significantly to operationalising the CDR vision through expertise within the sector as well as providing the Open Banking systems through which the first consumer data will flow in the CDR.

The ABA is supportive of modernising prudential guidance in line with contemporary credit risk management practices. However, it is important to ensure that any new guidance sits comfortably within a predictable and transparent regulatory framework for ADIs

The ABA asks APRA to consider the ARS 115 consistency with the accounting standard and consistency with current data consultation outcomes.