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 welcomes the opportunity to comment on the exposure draft Treasury Laws Amendment Bill 2026: Tax information reporting (Exposure Draft) and explanatory materials (EM). The ABA su ports improving tax transparency and maintaining Australia’s alignment with international reporting standards. This submission builds on the ABA’s March 2026 letter.
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).