Economy-wide Cash Payment Limit
12 August 2019
The Australian Banking Association (ABA) supports the Government’s introduction of an economy-wide cash payment limit to businesses for goods and services. Having a taxation system that is robust and one that meets community expectations is vital and we recognise the importance of this initiative to the integrity of our tax system.
Download PDFConsultation Paper 313 – Product Intervention Power and draft Regulatory Guide
7 August 2019
We acknowledge The Australian Securities and Investments Commission’s (ASIC) intention to provide ‘high level’ guidance, and to rely on the ordinary meaning of ‘significant detriment’. However, for the efficient implementation of this measure, maximum clarity around the meaning of this term is desirable.
Download PDFOpen Banking designation instrument consultation (2nd round)
11 July 2019
Banking will be the first sector to apply the Consumer Data Right and the ABA supports the participation of more sectors over time to achieve an economy-wide open data regime.
Download PDFAPRA consultation on APS 220 Credit Risk Management
5 July 2019
The ABA welcomes the timely review of APS 220 to incorporate the new developments in credit risk management practices, including the new accounting standards and the Basel Committee supervisory guidance on sound credit risk practices. The ABA agrees that effective management of credit risk is a critical component of a comprehensive approach to risk management... Read more »
Download PDFComments on the Working Draft of the Consumer Data Standards
21 June 2019
ABA’s submission to Data 61 on Consumer Data Rights Standards 0.9.3 highlighted the need for a number of important functional and security requirements to be embedded in the regime.
Download PDFConsultation on revisions to prudential practice guide APG 223 residential mortgage lending
21 June 2019
The ABA welcomes APRA’s revision of the current buffer and floor limits set in December 2014.
Download PDFConsultation on responsible lending (RG209)
20 May 2019
The ABA is concerned that a move away from a principles based approach will negatively affect competition.
Download PDFAustralian Law Reform Commission Corporate Crime Inquiry
17 May 2019
It is important that any consideration of the liability of individuals for corporate misconduct take account of the various avenues pursuant to which individuals might be personally liable for corporate misconduct under the law as it stands.
Download PDFPrudential Practice Guide CPG 234 Information Security
17 May 2019
The ABA’s has specific comments on the following chapters: Third parties and related parties Implementation of controls Internal audit Attachment B: Training and awareness Attachment C: Identity and access
Download PDFACCC Draft Consumer Data Rules
10 May 2019
The ACCC’s draft Rules provide a good foundation for the implementation of open banking, however there are a number of areas that have not been addressed in the draft Rules or which require further guidance.
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New 2019 Banking Code of Practice
The new Banking Code is a set of enforceable standards that customers, small businesses, and their guarantors can expect from Australian banks.