6 July 2021
The ABA and members are supportive of APRA’s move to data collection based on a concept-dimension data model. ABA members broadly support the approach APRA has outlined in their letter of June 8. The collective view of ABA members is that a successful implementation will result from sufficient time being given to develop a full taxonomy, and that this is finalised well in advance of the first submission date so banks can build the infrastructure to support the data model. ABA members have concerns with the overlap of two new reporting requirements (the tactical solution and the incremental collections), the granular level of detail required for the strategic solution (especially for the lower risk portfolios) and the timing by which each reporting needs to be provided.
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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.