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
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.
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.