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 continues to support the intent of the CSLR as a last-resort scheme that compensates genuine victims where they have suffered actual financial loss as a result of financial misconduct that they have otherwise been unable to recover.
The Australian Banking Association (ABA) welcomes the opportunity to make a submission to the Treasury consultation Registry Stabilisation and Uplift – draft legislation (the consultation).
The Australian Banking Association welcomes the opportunity to comment on the Consultation Paper – 2026 Reforms to the AML/CTF Act.