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 ABA thanks ASIC for the opportunity to comment on its discussion paper on the dynamics between public and private markets.
The ABA welcomes APRA providing clarity on the proposed targeted changes for Higher Education Loan Program (HELP) debt obligations and the constructive approach it is taking on this consultation.
The ABA welcomes APRA’s consultative approach to the potential impacts of the proposed replacement of AT1 capital with higher amounts of CET1 and Tier 2 capital under APRA’s prudential framwork in Australia.