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reassurance that the specific items in the forms which are non-confidential but not proposed to be published, will not be published without further consultation.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 Australian Banking Association (‘ABA’) welcomes the opportunity to make this submission to the Review of the Reserve Bank of Australia. The ABA notes the significant role of Australia’s central bank in delivering good economic outcomes for the nation. We support the ongoing independence of the Reserve Bank of Australia in executing its mandate.
The ABA’s responses to the panel’s questions in the Issues Paper (15 September 2022) raises these key points:
– We consider the three objectives to be appropriate, noting there may be an opportunity to update the expression of the objectives in Section 10(2) of the Reserve Bank Act (1959).
– We see opportunities for Reserve Bank of Australia (‘the RBA’ or ‘the Bank’) to augment its communications to explain the complexities underlying the decisions as well as greater explanation of the trade-offs made between the Bank’s objectives.
– We see the independence of the RBA as critical to ensuring a well-functioning economy.
Australian Banks support the intent of this global agreement to address the risks and leverage the opportunities arising from the digitalisation of the global and domestic economy. The ABA recommends that where possible, Australia’s implementation of the proposes measures should align with existing reporting and administrative requirements, and should be consistent with international approaches to ensure a streamlined and effective implementation.
The ABA considers the ASIC industry funding model is broadly meeting its objectives. The funding model promotes equitable outcomes across the financial services industry and for the community, by ensuring that entities that create the need for regulation bear the costs rather than taxpayers. However, there is scope to increase the transparency of the ASIC funding and improve some aspects of the reporting mechanisms.