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reassurance that the specific items in the forms which are non-confidential but not proposed to be published, will not be published without further consultation.
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The ABA thanks ASIC for the opportunity to comment on its discussion paper on the dynamics between public and private markets.
The ABA welcomes APRA providing clarity on the proposed targeted changes for Higher Education Loan Program (HELP) debt obligations and the constructive approach it is taking on this consultation.
The ABA welcomes APRA’s consultative approach to the potential impacts of the proposed replacement of AT1 capital with higher amounts of CET1 and Tier 2 capital under APRA’s prudential framwork in Australia.