20 April 2018
The ABA recommends that the draft legislative instrument be amended so that a ‘small ADI’ would be defined as having less than or equal to $30 billion total resident assets rather than the current definition of having less than or equal to $10 billion total resident assets (on a three-year average).
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The Australian Banking Association welcomes the opportunity to comment on the Consultation Paper – 2026 Reforms to the AML/CTF Act.
The ABA appreciates the opportunity to contribute to the RBA’s Review of Merchant Payment Costs and Surcharging (Proposals Paper).
The ABA thanks ASIC for the opportunity to comment on its discussion paper on the dynamics between public and private markets.