Critical Infrastructure Bill 2020
12 February 2021
The ABA has recommended a number of changes be made to the Bill enshrining verbal assurances already provided by the Department of Home Affairs. The ABA also proposes early consultation with industry to ensure time and resources for compliance, and to ensure guidance as to what information the government may require from critical infrastructure entities and the nature of information sharing between government and critical infrastructure sectors.
Download PDFTreasury consultation on licensing debt management firms
12 February 2021
The ABA supports the Government’s proposal to licence debt management and credit repair firms. We believe that all Australians should be afforded consistent consumer protections, no matter which credit or financial services provider they choose.
Download PDFCredit Reform
3 February 2021
The Australian Banking Association (ABA) supports the Government’s reforms to the National Consumer Credit Protection Act. So much has changed since 2009 that it is only sensible for the Government to review the legislative and regulatory framework. Ensuring the efficient flow of credit into the economy with strong consumer protections in place will assist Australia’s recovery from the pandemic.
Download PDFSubmission to the Payments System Review
29 January 2021
The ABA strongly supports continuing the self-regulatory arrangements within our regulatory architecture. The payments regulatory architecture should support innovation, as well as ensure the stability, and security of an expanded payments ecosystem. Innovation in payments should be considered through the lens of consumer and business end-users. These users rightly expect that when they make a payment, whether this is done through traditional channels or via a new app, their payments will be made in a timely, safe and secure way and their data will be secure.
Download PDFDigital Identity Legislation: consultation paper
18 December 2020
Banks are actively exploring digital identity initiatives and see the benefit of collaboration between government and industry. The interests of the Australian economy will be better served if there is flexibility to innovate and respond to the needs of consumers and businesses, instead of establishing a single government digital identity scheme. Government can also achieve genuine collaboration with industry without legislation.
Download PDFResponse to Senate Select Committee on Fintech and RegTech
17 December 2020
The ABA urges the development of an overarching strategy for data and information privacy to underpin the transition to a digital economy and provide a consistent framework for future reforms. Co-ordination will be critical to achieve the intended outcomes. The data economy has the real and exciting potential to generate jobs and opportunities for servicing the needs of all Australians. Technology and digital capability are the mechanisms by which banking will continue to develop.
Download PDFPrivacy Act 1988 (Cth) Review
4 December 2020
The ABA supports a review of the Privacy Act and the stated goals to ensure privacy settings empower consumers, protect consumer data, and best serve the Australian economy. Achieving the balance between Personal Information (PI) protection, innovation and economic growth will require considerable time and effort from the AGD to get these reforms right. The ABA urges the government to first design an overarching blueprint and roadmap for data and information privacy. The ABA highlights at multiple points that the OAIC could provide further and specific guidance rather than embedding the detail in the Privacy Act.
Download PDFSecurity 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.
Download PDFResponse 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
Download PDFConsultation 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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