2 June 2021
The ABA considers that the review of the existing Regulator Performance Guide is timely. It is critical to ensure that regulation of the financial system does not inhibit the ability of financial firms to serve the Australian population or grow the economy.
The ABA supports the Government’s proposal to transition towards a more flexible and principles-based approach to regulator performance. We have developed our response with a focus on providing constructive suggestions to improve the potential scope and application of the three principles that are proposed with regard to financial regulation
Continuous improvement and building trust
Risk-based and data-driven
Collaboration and engagement
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To assist consistency of implementation across the industry, the Australian Banking Association has developed industry position on a range of aspects regarding the implementation of APRA’s revised capital framework.
The ABA welcomes APRA’s ongoing engagement regarding the implementation of the revised APS 117 and provides the attached estimate of the associated compliance costs.
Australian banks are using new technologies to increase efficiency and to provide new and more responsive services to customers. We propose the government focus on: simplifying or rationalising existing legislation that impact on the use of AI and ADM, in preference to new specific AI regulations; any regulatory intervention including setting best practice guidance should build on existing best practices and harmonise with sector specific regulation; and review and amend legislation to be neutral as to whether a human or technology is used to make decisions or conduct a process.