The Australian Bankers’ Association submission on APS 110 and APG 110

The ABA agrees that capital and funding, tax, skills and talent, culture and regulation are key factors that determine Australia’s competitive position to attract and maintain investment in technology. However, the ABA respectfully requests to also consider how Australia should best manage data in the emerging digital economy.

The ABA supports the alignment of APS 117 with the Basel Committee on Banking Supervision interest rate risk in the banking book issued April 2016 where appropriate.

The ABA supports ASIC finalising this review and releasing updated regulatory guidance as soon as possible to provide clarity and assist credit licensees comply with their responsible lending obligations.