Review of the Intergovernmental Agreement for an Electronic Conveyancing National Law

An earlier implementation date for the revised operational risk capital requirements will be difficult and should be optional.

The ABA welcomes the IGA review and is in general, supportive of its findings, draft recommendations and the draft options for improvement.

The ABA supports appropriate cost reflective funding of APRA. An adequately resourced regulator will ensure its regulatory mandate is undertaken in a timely and effective way.