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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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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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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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APRA: Capital Framework Revisions Draft Guidance

14 March 2022

The ABA continues to support a revised capital framework that strengthens the financial resilience of the industry, embeds the industry’s unquestionably strong level of capital and provides for greater flexibility in periods of stress. ABA member banks are actively working towards the implementation of APRA’s revised capital framework. Considerable work still remains in both defining and implementing the framework based on the practice guides issued as well as implementing related changes to regulatory reporting, modifications to Pillar 3 and international comparability studies, and updates to related standards.

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Proposed changes to quarterly ADI statistical publications

3 March 2022

The ABA supports changes to the templates of quarterly ADI statistics due to the associated changes with APRA Reporting Standards 220, 223 and 230. The ABA recommends proactively delaying first publication of the new quarterly ADI statistics beyond the June 14 date to ascertain and correct any possibly data quality issues resulting from the implementation of the new reporting standards.

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Macroprudential and APS 220

25 February 2022

Increasing the macroprudential policy options available to APRA and transparency regarding when and how they may be used, should assist with enhancing the financial stability and resilience of the Australian economy. The ABA is supportive of these measures which offer a useful complement to the resilience provided by Australia’s well capitalised and well managed banks. In developing and implementing market interventions, such as macroprudential policies, it is vitally important that unintended consequences, regulatory burden and competition distortions are minimised. As such, and considering the system wide consequences of macroprudential interventions, the ABA strongly recommends APRA incorporates and imbeds processes to ensure early and close engagement with the banking industry before any macroprudential policies are implemented. Additional recommendations and points for clarification are included in the ABA’s submission to APRA.

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Reporting Standard ARS 720.1

8 September 2021

We request that the new ARS 720.1 come into effect on 1 March 2022 so that both ARF 220.0 and ARF 720.1 will be first prepared on the new standards consistently for the period ended 31 March 2022.

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Bank Capital Reforms: Update

20 August 2021

We support a revised capital framework that strengthens the financial resilience of the industry, embeds unquestionably strong levels of capital and also provides for greater flexibility in periods of stress. We recommend that APRA: • replace the parallel run with targeted quantitative impact surveys (QIS) • delay the implementation of the standardised approach for foundation and advanced internal ratings based (FIRB and AIRB) authorised deposit-taking institutions (ADIs) • reduce the regulatory reporting burden on ADIs for March 2023, and • delay the implementation of new Pillar 3 changes to 2024.

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APRA consultation on zero and negative interest rates

20 August 2021

Given the uncertainties arising from the COVID-19 pandemic and the related economic impacts, the ABA understands the importance of ensuring systemic stability and preparedness of members for a range of risks, including a zero or negative cash rate. The ABA considers the timing of the development of solutions by 30 April 2022 may be insufficient given the impact that these solutions would have to ADI core banking systems, processes and potential amendments to product terms and conditions.

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