8 October 2021
Currently, significant delay, financial costs and opportunity costs result from the need to sign and witness deeds and statutory declarations on paper; these costs also result from inconsistent and
uncertain regulations under Commonwealth, State and Territory laws.
The ABA strongly advocates for the reforms to remain technology neutral and provide a single, consistent approach to executing deeds and statutory declarations. Otherwise the reforms may make it
harder to use, and therefore disincentivise the use of, electronic execution.
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.