The ABA supports the inclusion of TPSPs within the CDR regime. TPSPs could play an important role in the efficient and cost-effective provision of services to consumers. The entry of TPSPs, with appropriate governance and consumer protections, will enable the development of a richer and more vibrant ecosystem.

The ABA supports a principled approach to policy making on Commonwealth criminal responsibility. Such an approach stands to enhance confidence in the regulatory framework by providing consistent, predictable treatment of conduct across the regulatory landscape.

The ABA supports the codification of the expectation that where one regulator possesses information about an obvious and significant breach of laws administered by the other, the regulator should pass that information on. This will ensure early detection of misconduct and swifter enforcement action.