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reassurance that the specific items in the forms which are non-confidential but not proposed to be published, will not be published without further consultation.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 welcomes the Government’s establishment of the Deregulation Taskforce (Taskforce). The proposed reforms to modernise business communications have the potential to reduce business costs and reflect the way Australian consumers and businesses prefer to manage their financial affairs today. The ABA particularly welcomes the Taskforce’s whole-of-economy approach by working to improve technology neutrality across Commonwealth laws, and importantly – partnering with states and territories to explore opportunities to achieve national consistency.
The ABA has recommended a number of changes be made to the Bill enshrining verbal assurances already provided by the Department of Home Affairs.
The ABA also proposes early consultation with industry to ensure time and resources for compliance, and to ensure guidance as to what information the government may require from critical infrastructure entities and the nature of information sharing between government and critical infrastructure sectors.
The ABA supports the Government’s proposal to licence debt management and credit repair firms. We believe that all Australians should be afforded consistent consumer protections, no matter which credit or financial services provider they choose.