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reassurance that the specific items in the forms which are non-confidential but not proposed to be published, will not be published without further consultation.
The ABA supports in principle the inclusion of compliance powers in the Electronic Conveyancing National Law (ECNL). However, the ABA considers it critical that the Australian Registrars National Electronic Conveyancing Council (ARNECC) is constituted with the appropriate understanding of the technical and operational details of interoperability, including financial settlement, to enforce its proposed new powers… Read more »
The ABA acknowledges the intent of the RIC in supporting agribusinesses during periods of difficulty, such as natural disaster and drought. While the ABA acknowledges these additional loan categories may be valuable to eligible farmers, we note the RIC was first set up for the purpose of supporting drought affected farmers who may not have… Read more »
The ABA continues to support establishment of the Housing Australia Future Fund as a mechanism to provide a sustainable funding source to support and increase the development of social and affordable housing during a critical period of lower than required housing supply. The ABA acknowledges that other industry factors such as planning, and the cost… Read more »