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.
The ABA seeks clarification, but welcomes APRA’s approach by requiring a credit assessment to be ‘appropriate’. The ABA welcomes greater data transparency by regulators, but has a list of recommendations for ARS 923.3.
The response incorporates initiatives on loan deferrals and lending, banking accessibility, and electronic conveyancing and electronic mortgages. These measures were designed to support consumers and businesses through this difficult time and intended to mitigate the impacts of COVID-19 on bank