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.Download PDF
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.