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Pragmatic implementation of APG 110, APG 112 and APG 113

6 June 2022

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.

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APS 117 Compliance Costs

24 May 2022

The ABA welcomes APRA’s ongoing engagement regarding the implementation of the revised APS 117 and provides the attached estimate of the associated compliance costs.

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Automated Decision Making and AI Regulation

20 May 2022

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.

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Statutory Review of the Consumer Data Right

20 May 2022

The ABA makes a number of recommendations to improve the rollout of the Consumer Data Right, including prioritising changes that benefit consumers the most, simplify and streamline regulatory requirements and prioritise broader payments reforms before rolling out write-access.

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Mandating eConveyancing in Queensland

5 May 2022

The Australian Banking Association continues to support efforts to accelerate the adoption of electronic mortgages and settlement for the convenience of consumers and the associated economic benefits. The banking industry is supportive of mandating electronic conveyancing in Queensland, which is a pragmatic and natural development from the current regime. Mandating e-conveyancing in Queensland will create greater certainty for consumers and drive greater efficiencies.

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ABA Letter on PPG (110, 112, 113)

30 April 2022

To assist APRA finalise the prudential practice guides (APG 110, APG 112 and APG 113), industry provides the attached feedback in response to: 1) the materials presented to the industry in the APRA-ABA workshop on 8 April; and 2) the subsequent queries to industry on 19 April.

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ARNECC: Independent Health Checks and Readiness Assessments of the Interoperability Reform

21 April 2022

The ABA is supportive of implementing ongoing and independent health checks, to review the risks to and status of the national roll-out of interoperability. The banking industry is also supportive of the proposed three phase approach.

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Basel III liquidity ratios: post-implementation review

14 April 2022

The Australian Banking Association welcomes the opportunity to respond to the Australian Prudential Regulation Authority’s discussion paper, Post-implementation Review of the Basel III Liquidity Ratios in Australia, which focuses on the Liquidity Coverage Ratio (LCR) and the Net Stable Funding Ratio (NSFR). The LCR and NSFR were and remain important elements of the Basel III Liquidity reforms. Overall, these liquidity measures have achieved their objectives of promoting short-term and long-term resilience of banks’ liquidity and funding profiles and are supported by the banking industry.

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Extension of the Consumer Data Right to non-bank lending

14 April 2022

Response to Treasury's consultation on the extension of the Consumer Data Right to non-bank lending. In this submission, the ABA responds to some issues raised in the discussion paper and provides comment based on the experience of banks in implementing the CDR.

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Climate Change Authority International Offsets

14 April 2022

The ABA encourages continuous improvement in the operating features of carbon markets to improve integrity and trust and to build scale and liquidity.

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