7 August 2019
We acknowledge The Australian Securities and Investments Commission’s (ASIC) intention to provide ‘high level’ guidance, and to rely on the ordinary meaning of ‘significant detriment’. However, for the efficient implementation of this measure, maximum clarity around the meaning of this term is desirable.Download PDF
An earlier implementation date for the revised operational risk capital requirements will be difficult and should be optional.
The ABA welcomes the IGA review and is in general, supportive of its findings, draft recommendations and the draft options for improvement.
The ABA supports appropriate cost reflective funding of APRA. An adequately resourced regulator will ensure its regulatory mandate is undertaken in a timely and effective way.