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 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.
The Australian Banking Association (ABA) welcomes the opportunity to make a submission to the Treasury consultation Registry Stabilisation and Uplift – draft legislation (the consultation).
The Australian Banking Association welcomes the opportunity to comment on the Consultation Paper – 2026 Reforms to the AML/CTF Act.