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reassurance that the specific items in the forms which are non-confidential but not proposed to be published, will not be published without further consultation.
Download PDFConsultation 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.
Download PDFProposed 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.
Download PDFAPRA consultation on treatment of loans impacted by COVID-19
21 August 2020
The ABA seeks clarification, but welcomes APRA’s approach by requiring a credit assessment to be ‘appropriate'. The ABA welcomes greater data transparency by regulators, but has a list of recommendations for ARS 923.3.
Download PDFAPG 220 Credit Risk Management Submission
19 March 2020
The ABA is supportive of modernising prudential guidance in line with contemporary credit risk management practices. However, it is important to ensure that any new guidance sits comfortably within a predictable and transparent regulatory framework for ADIs
Download PDFRevisions to APS 111 Capital Adequacy: Measurement of Capital
14 February 2020
The ABA supports APRA’s review of the capital framework but asks for further consideration of investment in regulated subsidiaries.
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