20 August 2021
The ABA supports maintaining an excess reserve of eligible assets for contingent funding to ensure stability during periods of stress. However, we have concerns regarding the revised requirements as currently proposed by APRA.
In particular:
1. It is well-above international standards
2. It is proposed to include offshore operations
3. It is to apply at all times
4. An implementation pathway has not been proposed
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The Australian Banking Association welcomes the opportunity to comment on the Consultation Paper – 2026 Reforms to the AML/CTF Act.
The ABA appreciates the opportunity to contribute to the RBA’s Review of Merchant Payment Costs and Surcharging (Proposals Paper).
The ABA thanks ASIC for the opportunity to comment on its discussion paper on the dynamics between public and private markets.