20 August 2021
We support a revised capital framework that strengthens the financial resilience of the industry, embeds unquestionably strong levels of capital and also provides for greater flexibility in periods of stress.
We recommend that APRA:
• replace the parallel run with targeted quantitative impact surveys (QIS)
• delay the implementation of the standardised approach for foundation and advanced internal ratings based (FIRB and AIRB) authorised deposit-taking institutions (ADIs)
• reduce the regulatory reporting burden on ADIs for March 2023, and
• delay the implementation of new Pillar 3 changes to 2024.
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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).
The ABA continues to support the intent of the CSLR as a last-resort scheme that compensates genuine victims where they have suffered actual financial loss as a result of financial misconduct that they have otherwise been unable to recover.