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.
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.
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.