12 November 2018
While the ABA supports ‘unquestionably strong’ capital ratios, the ABA agrees with APRA that this embedded conservatism makes it more difficult and/or costly for Australian ADIs to access international capital markets if these Australian differences are not well understood, particularly during times of market dislocation.Download PDF
ABA’s submission to Data 61 on Consumer Data Rights Standards 0.9.3 highlighted the need for a number of important functional and security requirements to be embedded in the regime.
The ABA welcomes APRA’s revision of the current buffer and floor limits set in December 2014.
The ABA’s has specific comments on the following chapters: Third parties and related parties Implementation of controls Internal audit Attachment B: Training and awareness Attachment C: Identity and access