Protecting Critical Infrastructure and Systems of National Significance

The ABA strongly supports the Government’s desire to build on rather than duplicate existing regulation. A harmonised approach is critical to the implementation of these reforms in the banking industry. A single regulator having a clear mandate and a transparent system in place for regulatory co-ordination for banks – a model that may be relevant for other parts of the banking and financial services sector and other sectors.

The ABA seeks clarification, but welcomes APRA’s approach by requiring a credit assessment to be ‘appropriate’. The ABA welcomes greater data transparency by regulators, but has a list of recommendations for ARS 923.3.

The ABA believes that deposits are currently protected and could not be bailed in during the resolution process of any ADI.