19 September 2019
The ABA acknowledges the breadth of the report and supports initiatives to improve privacy protections for banking customers. The ABA makes several points in this submission which warrant further review of recommendations 16-17 with respect to privacy, and also recommendations 20-21 with respect to unfair contract terms and unfair practices, and data portability.
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The ABA thanks ASIC for the opportunity to comment on its discussion paper on the dynamics between public and private markets.
The ABA welcomes APRA providing clarity on the proposed targeted changes for Higher Education Loan Program (HELP) debt obligations and the constructive approach it is taking on this consultation.
The ABA welcomes APRA’s consultative approach to the potential impacts of the proposed replacement of AT1 capital with higher amounts of CET1 and Tier 2 capital under APRA’s prudential framwork in Australia.