27 November 2019
The ABA recommends that the PS GL undergo a second consultation twelve months after the launch of the CDR regime. The ABA recommends that the OAIC institutes a process for annual review (or as CDR documentation is revised) of the PS GL in order to ensure that all cross-references remain up-to-date, complete, relevant and therefore effective. It would benefit readers of the PS GL if the OAIC provided multiple examples where a Privacy Safeguard requires DHs and ADRs to consider what is ‘reasonably needed’ or ‘proportionate’.Download PDF
The ABA asks APRA to consider the ARS 115 consistency with the accounting standard and consistency with current data consultation outcomes.
The ABA strongly supports the Government’s initiative to help small businesses grow by coinvesting with banks to establish this Australian Business Growth Fund. The Fund is designed to provide equity finance to qualifying businesses across a range of industries and locations.
The ABA supports APRA’s review of the capital framework but asks for further consideration of investment in regulated subsidiaries.