1 April 2021
The ABA recommends that the final policy settings accurately reflect the proven resilience of banks and the needs of the Australian economy.
The ABA also expects further calibration to be undertaken to ensure there is no increase to the overall level of capital in the banking system, considers that the proposed application of a non-standard treatment to interest-only mortgages with terms greater than five years is unduly punitive, considers that the proposed capital allocation to New Zealand exposures at Level 2 is set at a conservative level that is not commensurate with the level of risk
ABA members also feel consideration should be given to increasing the default level of the proposed CCyB, it considers that the required IT updates makes the 1 January 2023 commencement date challenging, encourages APRA to promptly update its 2015 International capital comparison study and some of APRA’s current proposals may amplify volatility without necessarily improving the measurement of risk.
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The ABA Submission is supportive of the Landgate’s efforts to enable the creation and execution of documents in electronic form. The ABA provides answers to the specific questions in the Landgate consultation paper.
The Australian Banking Association (ABA) welcomes Australia Prudential Regulation Authority’s (APRA) ongoing and constructive engagement, and the opportunity to respond to the policy options on the revised draft Prudential Standard APS 117 Capital Adequacy: Interest Rate Risk in the Banking Book (APS 117), which were presented to industry on 18 May 2023.
The ABA submission to the Senate Economic Committee, the submission addresses the importance of certainty regarding capital raises and distributions to banks.