8 February 2023
The Australian Banking Association (ABA) broadly supports the intention of the National Reconstruction Fund Corporation Bill 2022 and the National Reconstruction Fund (Fund), which is expected to support and diversify Australia’s emerging industry sectors but has some concerns in relation to the Fund’s design and implementation, including the proposed priority areas, scope of the investment mandate and how these matters may impact on the crowding out of the private sector market that is otherwise willing and able to invest in these areas. It is noted that banks already invest in many of the priority areas proposed by the Government and investments in these areas would be better suited towards the beginning of their lifecycle where it is more difficult for banks to manage the risk profile. The ABA recommends it being a requirement of the investment mandate to consult with traditional private sector participants before making an investment by the Fund, such as via a panel of financiers. Government should assess the commerciality of each prospective investment and refer it to the private sector where it is sensible to do so from the perspective of return and/or risk appetite.
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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.