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Security Legislation Amendment (Critical Infrastructure) Bill 2020

27 November 2020

The ABA proposes a small number of changes that would make these policy outcomes clear on the face of legislation and provide flexibility for the regime to address issues specific to one or more critical sectors. The ABA also reiterates that a harmonised approach, where a single regulator has a clear mandate and a transparent system in place for regulatory coordination, will ensure critical assets in the banking sector are secure and resilient.

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Response to Treasury Consultation on Consumer Credit Reforms

24 November 2020

The Australian Banking Association (ABA) supports the Government’s Consumer Credit Reforms. These important reforms will strike the right balance between maintaining strong consumer protections while providing credit into the economy at a critical time. The ABA supports: Maintaining strong consumer protections Consistent consumer protection and level playing field Simplification and removing duplication Support for complementary reforms

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Consultation on confidentiality of key ADI metrics

20 November 2020

An approach which supports APRA’s first proposal while overcoming the governance, timing and definitional issues outlined in this letter, is for APRA to publish only Level 2 capital, liquidity and asset quality items aligned with Pillar 3 after all entities have first disclosed the information to market. The ABA supports APRA publishing data on a quarterly basis which is already reported under Pillar 3 requirements. The ABA recommends APRA publish data only after ADIs have already disclosed it. The ABA recommends that before making any data non-confidential or public, APRA conduct their own audit of data definitions to identify and rectify any gaps in the taxonomy. The ABA recommends APRA only make non-confidential and publish Level 2 data. The ABA recommends APRA provide written reassurance that the specific items in the forms which are non-confidential but not proposed to be published, will not be published without further consultation.

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ABA Response to Pottinger Review

13 November 2020

The Review is an important measure in clarifying the definition of small businesses in Australia and the ABA accepts all nine recommendations.

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Consultation on the Data Availability and Transparency (DAT) Bill 2020

6 November 2020

The ABA supports the broad policy that public sector data should be able to be shared with appropriate safeguards if doing so is in the public interest, under the proposed regime (DAT regime). However, the ABA considers the Bill as drafted would significantly undermine Commonwealth regimes that have enabled effective business regulation in banking and other critical economic sectors. As such, the ABA strongly urges the Government to provide an exclusion for data that is covered by existing confidentiality provisions in regulatory regimes, such as section 56 of the APRA Act 1998, and consider alternative means of achieving this policy objective in relation to this class of data.

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Corporations Amendment (Virtual Meetings and Electronic Communications) Bill 2020

30 October 2020

We strongly welcome the Government’s proposal to make the electronic execution of company documents and virtual meetings reforms permanent for the benefit and convenience of customers and to improve efficiencies in the processing of critical documents. The ABA considers: • Deeds should be able to be created and signed electronically by companies and individuals. • Electronic signatures rather than wet signatures should be able to be used for a broader range of legal and business documents. • Remote witnessing should be legally valid.

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ABA Commentary on Proposed Expansions to CDR Rules 2020

29 October 2020

The ABA does not support the proposed segmentation of banking data into high, medium, and low risk. The speed at which the Australian Competition and Consumer Commission (ACCC) intends to finalise the draft Rules is concerning, especially given risks which have been raised in the Privacy Impact Assessment (PIA). The ABA does not believe that it is possible for the ACCC to mitigate the risks raised in the PIA and concurrently resolve the questions and concerns raised in this submission by December 2020. The ABA is particularly concerned with negative impacts the speed of implementation will have on smaller banks. The ABA is also concerned that consumers may be overwhelmed with the level of complexity in the proposed Rules which may make them less likely to participate in the CDR. Trust in the security of the CDR is paramount to its success. The ABA urges the ACCC to reconsider the intention to finalise these rules by December 2020 and seeks a meeting with the ACCC to discuss the concerns raised in this submission

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Consumer Data Right On-boarding – Feedback

23 October 2020

The ABA believes that this process flow will benefit from an additional step ‘Testing’. The ABA recommends that testing stages which are aligned to those documented in the ACCC’s ‘Assurance Strategy Consumer Data Right’ (28/8/19) should be implemented for all data holders.

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Protecting Critical Infrastructure and Systems of National Significance

16 October 2020

The ABA strongly supports the Government’s desire to build on rather than duplicate existing regulation. A harmonised approach is critical to the implementation of these reforms in the banking industry. A single regulator having a clear mandate and a transparent system in place for regulatory co-ordination for banks - a model that may be relevant for other parts of the banking and financial services sector and other sectors.

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Proposed APRA Performance Measures

24 September 2020

The ABA welcomes the timely review of APRA’s performance measures and supports more streamlined performance metrics. Developing new metrics is an opportunity for APRA to clearly demonstrate how it is implementing best practice and considering the compliance costs in its decision making holistically.

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