20 August 2021
Given the uncertainties arising from the COVID-19 pandemic and the related economic impacts, the ABA understands the importance of ensuring systemic stability and preparedness of members for a range of risks, including a zero or negative cash rate.
The ABA considers the timing of the development of solutions by 30 April 2022 may be insufficient given the impact that these solutions would have to ADI core banking systems, processes and potential amendments to product terms and conditions.
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To assist consistency of implementation across the industry, the Australian Banking Association has developed industry position on a range of aspects regarding the implementation of APRA’s revised capital framework.
The ABA welcomes APRA’s ongoing engagement regarding the implementation of the revised APS 117 and provides the attached estimate of the associated compliance costs.
Australian banks are using new technologies to increase efficiency and to provide new and more responsive services to customers. We propose the government focus on: simplifying or rationalising existing legislation that impact on the use of AI and ADM, in preference to new specific AI regulations; any regulatory intervention including setting best practice guidance should build on existing best practices and harmonise with sector specific regulation; and review and amend legislation to be neutral as to whether a human or technology is used to make decisions or conduct a process.