28 October 2019
The ABA views any changes to the Consumer Data Right (CDR) regime as likely to have a significant impact on the privacy of individuals, thereby warranting reconsideration of the risks and recommendations made by the PIA. This review process is crucial to ensuring that the CDR regime will meet its stated goal of being ‘consumer… Read more »Download PDF
The ABA supports the inclusion of TPSPs within the CDR regime. TPSPs could play an important role in the efficient and cost-effective provision of services to consumers. The entry of TPSPs, with appropriate governance and consumer protections, will enable the development of a richer and more vibrant ecosystem.
The ABA supports a principled approach to policy making on Commonwealth criminal responsibility. Such an approach stands to enhance confidence in the regulatory framework by providing consistent, predictable treatment of conduct across the regulatory landscape.
The ABA supports the codification of the expectation that where one regulator possesses information about an obvious and significant breach of laws administered by the other, the regulator should pass that information on. This will ensure early detection of misconduct and swifter enforcement action.