Proposed APRA Performance Measures

The ABA proposes a small number of changes that would make these policy outcomes clear on the face of legislation and provide flexibility for the regime to address issues specific to one or more critical sectors.

The ABA also reiterates that a harmonised approach, where a single regulator has a clear mandate and a transparent system in place for regulatory coordination, will ensure critical assets in the banking sector are secure and resilient.

The Australian Banking Association (ABA) supports the Government’s Consumer Credit Reforms. These important reforms will strike the right balance between maintaining strong consumer protections while providing credit into the economy at a critical time. The ABA supports:

Maintaining strong consumer protections
Consistent consumer protection and level playing field
Simplification and removing duplication
Support for complementary reforms

An approach which supports APRA’s first proposal while overcoming the governance, timing and definitional issues outlined in this letter, is for APRA to publish only Level 2 capital, liquidity and asset quality items aligned with Pillar 3 after all entities have first disclosed the information to market.

The ABA supports APRA publishing data on a quarterly basis which is already reported under Pillar 3 requirements.
The ABA recommends APRA publish data only after ADIs have already disclosed it.
The ABA recommends that before making any data non-confidential or public, APRA conduct their own audit of data definitions to identify and rectify any gaps in the taxonomy.
The ABA recommends APRA only make non-confidential and publish Level 2 data.
The ABA recommends APRA provide written reassurance that the specific items in the forms which are non-confidential but not proposed to be published, will not be published without further consultation.