26 November 2019
The ABA strongly supports the retention of a principles-based approach to responsible lending through
the legislative provisions contained in the NCCP Act, as well as in relation to relevant regulatory
guidance, including in ASIC’s RG 209 and APRA’s APG 223 and APS 220.
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.