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reassurance that the specific items in the forms which are non-confidential but not proposed to be published, will not be published without further consultation.
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To assist consistency of implementation across the industry, the Australian Banking Association has developed industry position on a range of aspects regarding the implementation of APRA’s revised capital framework.
The ABA welcomes APRA’s ongoing engagement regarding the implementation of the revised APS 117 and provides the attached estimate of the associated compliance costs.
Australian banks are using new technologies to increase efficiency and to provide new and more responsive services to customers. We propose the government focus on: simplifying or rationalising existing legislation that impact on the use of AI and ADM, in preference to new specific AI regulations; any regulatory intervention including setting best practice guidance should build on existing best practices and harmonise with sector specific regulation; and review and amend legislation to be neutral as to whether a human or technology is used to make decisions or conduct a process.