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).Download PDF
An earlier implementation date for the revised operational risk capital requirements will be difficult and should be optional.
The ABA welcomes the IGA review and is in general, supportive of its findings, draft recommendations and the draft options for improvement.
The ABA supports appropriate cost reflective funding of APRA. An adequately resourced regulator will ensure its regulatory mandate is undertaken in a timely and effective way.