3 September 2021
The ABA supports recently enacted legislative changes to the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (AML/CTF Act) that require reporting entities to verify their customers’ identity before providing designated services.
The ABA also supports the provision for special circumstances that justify carrying out applicable customer identification procedures (ACIP) after the commencement of a designated service. While generally in support of this Chapter, the ABA seeks additional clarity over the scope of the proposed special circumstances, particularly in relation to opening an account and the initial deposit.
We also support broader changes proposed to Chapters 21 and 48 of the rules. The submission puts forward a proposal regarding Chapter 80 on the basis that there may be unintended consequences with the current drafting, such as exempting a broader range of activities.
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The ABA continues to support establishment of the Housing Australia Future Fund as a mechanism to provide a sustainable funding source to support and increase the development of social and affordable housing during a critical period of lower than required housing supply. The ABA acknowledges that other industry factors such as planning, and the cost… Read more »
The ABA acknowledges the work of ARNECC to date in developing the interoperability program. We continue to support the intention of interoperability on the basis that eConveyancing transactions under interoperability are substantively like those under a non-interoperable framework. However, the ABA has significant concerns that the interoperability program will be impacted by the failure to… Read more »
ABA members are committed to the success of Australia’s franchisors and franchisees, who play an important role in our economy.
The ABA supports retention of the Franchising Code of Conduct and the Franchise Disclosure Register and acknowledges the important role these tools have in protecting both franchisors and franchisees, which are often small businesses.
Entering a franchising arrangement is a significant legal and financial undertaking and it is sometimes the case that individuals who are attracted to franchising are also newer to business. Franchisees should be encouraged to undertake due diligence to ensure they are well informed about the risks and responsibilities, as well as their rights, prior to entering into their chosen franchising agreement.