6 December 2021
The ABA strongly recommends the Bill be amended to apply the OP Code more clearly and narrowly to the digital platforms on which the Inquiry focussed and the banking sector be expressly excluded from the definition of OP Organisations. The annexure provides detail in support of the recommendation. Additionally, in part two of the annexure we make suggestions in relation to the OP Code development, the OP Code scope and drafting matters relating to the Bill.
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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.