12 February 2021
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.
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Whilst the ABA supports the principle of a simple CDR, we question the ability to develop a ‘one-size-fits-all-sectors’ approach to joint accounts. The ABA supports retaining the current opt-in approach. The proposed opt-out approach is not supported on the basis that it undermines the foundational principle of the CDR, which is informed consent. We are of the view that it is not feasible to nominate an industry preferred option at this point.
While existing inquiries or reform initiatives touch on these policy issues, the issues are not confined to any single legislative framework or the responsibility of any single agency. They need a holistic assessment of potential policy solutions and their impact on consumers and the economy as a whole. A siloed approach may fail to consider the impact of specific recommendations or reforms on the Government’s policy to foster Australia’s digital economy and retain digital talent. As such, the ABA recommends robust coordination on policy and implementation that sees the oversight of mobile payment and digital wallet as a key plank of Australia’s digital economy.
The ABA welcomes an updated approach to new entrant ADIs focusing on sustainability. Providing pathways for restricted entry promotes competition through innovation amongst ADIs. The ABA agrees with APRA that an important balance needs to be made between supporting entities to both enter and thrive in the banking sector, while ensuring financial stability and protecting the interests of depositors.
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