24 July 2020
The banking industry is committed to working with government and stakeholders to develop workable and effective strategies and policy solutions to support those impacted by family, domestic and sexual violence related financial abuse.Download PDF
The ABA welcomes an updated approach to new entrant ADIs focusing on sustainability. Providing pathways for restricted entry promotes competition through innovation amongst ADIs. The ABA agrees with APRA that an important balance needs to be made between supporting entities to both enter and thrive in the banking sector, while ensuring financial stability and protecting the interests of depositors.
The ABA recommends that the final policy settings accurately reflect the proven resilience of banks and the needs of the Australian economy.
The ABA also expects further calibration to be undertaken to ensure there is no increase to the overall level of capital in the banking system, considers that the proposed application of a non-standard treatment to interest-only mortgages with terms greater than five years is unduly punitive, considers that the proposed capital allocation to New Zealand exposures at Level 2 is set at a conservative level that is not commensurate with the level of risk
ABA members also feel consideration should be given to increasing the default level of the proposed CCyB, it considers that the required IT updates makes the 1 January 2023 commencement date challenging, encourages APRA to promptly update its 2015 International capital comparison study and some of APRA’s current proposals may amplify volatility without necessarily improving the measurement of risk.
The ABA welcomes the Government’s establishment of the Deregulation Taskforce (Taskforce). The proposed reforms to modernise business communications have the potential to reduce business costs and reflect the way Australian consumers and businesses prefer to manage their financial affairs today. The ABA particularly welcomes the Taskforce’s whole-of-economy approach by working to improve technology neutrality across Commonwealth laws, and importantly – partnering with states and territories to explore opportunities to achieve national consistency.