13 December 2021
The ABA remains very supportive of the Treasury’s ongoing efforts to improve the technology neutrality of the Treasury portfolio and look forward to further engagement on this, and subsequent, tranches of legislative change.
Industry’s main comments regard allowing:
• (under National Credit Code (NCC)) the ‘publish and notify’ and ‘in any other way agreed to’ methods of communications which are permitted under the Corporations Act;
• more than one address to be used at any given time, which may be appropriate depending on the type of communications; and,
• communications via secure portals instead of an email address, as securely housing certain notifications and communications within the credit providers (CP) information system, where it can be retrieved by customers after appropriate authentication, better balances the need for accessibility, security and technology neutrality.
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The ABA thanks ASIC for the opportunity to comment on its discussion paper on the dynamics between public and private markets.
The ABA welcomes APRA providing clarity on the proposed targeted changes for Higher Education Loan Program (HELP) debt obligations and the constructive approach it is taking on this consultation.
The ABA welcomes APRA’s consultative approach to the potential impacts of the proposed replacement of AT1 capital with higher amounts of CET1 and Tier 2 capital under APRA’s prudential framwork in Australia.