19 March 2020
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
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The ABA strongly supports the Government’s desire to build on rather than duplicate existing regulation. A harmonised approach is critical to the implementation of these reforms in the banking industry. A single regulator having a clear mandate and a transparent system in place for regulatory co-ordination for banks – a model that may be relevant for other parts of the banking and financial services sector and other sectors.
The ABA seeks clarification, but welcomes APRA’s approach by requiring a credit assessment to be ‘appropriate’. The ABA welcomes greater data transparency by regulators, but has a list of recommendations for ARS 923.3.
The ABA believes that deposits are currently protected and could not be bailed in during the resolution process of any ADI.
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