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ADI centralised publication update and consultation

31 January 2023

ABA supports APRA’s decision to limit the first stage of ADI data publication to metrics which are aligned with bank Pillar 3 disclosures, while also noting there are some metrics which are not wholly consistent with these bank disclosures. Given the limited number metrics to be published, in contrast to the original proposal, ABA is comfortable with immediate publication on a quarterly frequency from June 2023.

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Revisions to the ADI Capital Framework

6 June 2022

The Australian Banking Association has provided feedback on the interim reporting standards and parallel run expectations for the ADI capital framework. This submission provides feedback on reporting timelines and dates, level of consolidation and scope of submissions as well as definitional questions relating to specific reporting standards

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APRA’s approach to new entrant ADIs

30 April 2021

The ABA welcomes an updated approach to new entrant ADIs focusing on sustainability. Providing pathways for restricted entry promotes competition through innovation amongst ADIs. The ABA agrees with APRA that an important balance needs to be made between supporting entities to both enter and thrive in the banking sector, while ensuring financial stability and protecting the interests of depositors.

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APRA: A more flexible and resilient capital framework for ADIs

1 April 2021

The ABA recommends that the final policy settings accurately reflect the proven resilience of banks and the needs of the Australian economy. The ABA also expects further calibration to be undertaken to ensure there is no increase to the overall level of capital in the banking system, considers that the proposed application of a non-standard treatment to interest-only mortgages with terms greater than five years is unduly punitive, considers that the proposed capital allocation to New Zealand exposures at Level 2 is set at a conservative level that is not commensurate with the level of risk ABA members also feel consideration should be given to increasing the default level of the proposed CCyB, it considers that the required IT updates makes the 1 January 2023 commencement date challenging, encourages APRA to promptly update its 2015 International capital comparison study and some of APRA’s current proposals may amplify volatility without necessarily improving the measurement of risk.

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