20 June 2018
This consultation is a step forward in improving the risk sensitivity, consistency and operational process of some aspects of the market risk framework. However, certain aspects of the framework remain excessively onerous, unduly complex and unrepresentative of the actual risk intended to be mitigated in smaller markets such as Australia.
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The ABA appreciates the opportunity to contribute to the RBA’s Review of Merchant Payment Costs and Surcharging (Proposals Paper).
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.