ABA submission on APRA Interest Rate Risk in the Banking Book workshop
2 June 2023
The Australian Banking Association (ABA) welcomes Australia Prudential Regulation Authority’s (APRA) ongoing and constructive engagement, and the opportunity to respond to the policy options on the revised draft Prudential Standard APS 117 Capital Adequacy: Interest Rate Risk in the Banking Book (APS 117), which were presented to industry on 18 May 2023.
Download PDFBank 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.
Download PDFContingent Liquidity: Proposed Guidance
20 August 2021
The ABA supports maintaining an excess reserve of eligible assets for contingent funding to ensure stability during periods of stress. However, we have concerns regarding the revised requirements as currently proposed by APRA. In particular: 1. It is well-above international standards 2. It is proposed to include offshore operations 3. It is to apply at all times 4. An implementation pathway has not been proposed
Download PDFAPRA: 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.
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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