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.
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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.