25 March 2022
Farm Debt Mediation (FDM) is widely acknowledged as a successful way for the farmer and the financier to resolve matters relating to farm business debts and, in many cases, is a preferred alternative to court. Most importantly, the FDM process provides an additional avenue for farmers in financial difficulty to either re-establish and maintain their viability or exit the industry with dignity. The ABA welcomes the review’s consideration of opportunities to enhance the Act and align with legislation in other states where possible.
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To assist consistency of implementation across the industry, the Australian Banking Association has developed industry position on a range of aspects regarding the implementation of APRA’s revised capital framework.
The ABA welcomes APRA’s ongoing engagement regarding the implementation of the revised APS 117 and provides the attached estimate of the associated compliance costs.
Australian banks are using new technologies to increase efficiency and to provide new and more responsive services to customers. We propose the government focus on: simplifying or rationalising existing legislation that impact on the use of AI and ADM, in preference to new specific AI regulations; any regulatory intervention including setting best practice guidance should build on existing best practices and harmonise with sector specific regulation; and review and amend legislation to be neutral as to whether a human or technology is used to make decisions or conduct a process.