20 November 2020
An approach which supports APRA’s first proposal while overcoming the governance, timing and definitional issues outlined in this letter, is for APRA to publish only Level 2 capital, liquidity and asset quality items aligned with Pillar 3 after all entities have first disclosed the information to market.
The ABA supports APRA publishing data on a quarterly basis which is already reported under Pillar 3 requirements.
The ABA recommends APRA publish data only after ADIs have already disclosed it.
The ABA recommends that before making any data non-confidential or public, APRA conduct their own audit of data definitions to identify and rectify any gaps in the taxonomy.
The ABA recommends APRA only make non-confidential and publish Level 2 data.
The ABA recommends APRA provide written reassurance that the specific items in the forms which are non-confidential but not proposed to be published, will not be published without further consultation.
Banks are actively exploring digital identity initiatives and see the benefit of collaboration between government and industry.
The interests of the Australian economy will be better served if there is flexibility to innovate and respond to the needs of consumers and businesses, instead of establishing a single government digital identity scheme.
Government can also achieve genuine collaboration with industry without legislation.
The ABA supports a review of the Privacy Act and the stated goals to ensure privacy settings empower consumers, protect consumer data, and best serve the Australian economy.
Achieving the balance between Personal Information (PI) protection, innovation and economic growth will require considerable time and effort from the AGD to get these reforms right.
The ABA urges the government to first design an overarching blueprint and roadmap for data and information privacy.
The ABA highlights at multiple points that the OAIC could provide further and specific guidance rather than embedding the detail in the Privacy Act.
The ABA proposes a small number of changes that would make these policy outcomes clear on the face of legislation and provide flexibility for the regime to address issues specific to one or more critical sectors.
The ABA also reiterates that a harmonised approach, where a single regulator has a clear mandate and a transparent system in place for regulatory coordination, will ensure critical assets in the banking sector are secure and resilient.