17 May 2019
The ABA’s has specific comments on the following chapters: Third parties and related parties Implementation of controls Internal audit Attachment B: Training and awareness Attachment C: Identity and accessDownload PDF
The ABA agrees that capital and funding, tax, skills and talent, culture and regulation are key factors that determine Australia’s competitive position to attract and maintain investment in technology. However, the ABA respectfully requests to also consider how Australia should best manage data in the emerging digital economy.
The ABA supports ASIC finalising this review and releasing updated regulatory guidance as soon as possible to provide clarity and assist credit licensees comply with their responsible lending obligations.