Submissions

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Capital treatment of mortgages under the First Home Loan Deposit Scheme

11 November 2019

The ABA welcomes further clarity on the capital treatment for guarantees under the Scheme. A clear understanding of the capital treatment is critical for an ADI’s mortgage product development and consequential approval under the scheme.

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Removal of the exemption for funeral expenses policies

18 October 2019

The ABA fully supports the removal of the exemption for funeral expenses policies from the defintion of financial products.

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Corporations Amendment (Design and Distribution Obligations) Regulations 2019

11 October 2019

The ABA welcomes the exclusion from the requirement to provide a Target Market Determination (TMD) of credit provided wholly or predominantly for business purposes. In implementing this legislation, it is important that the principle of scalability be flexibly applied and that clear guidance be given on this by ASIC. We welcome the clarification around the... Read more »

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ASIC Enforcement Review Taskforce

11 October 2019

The ABA supports stronger powers for ASIC and a strengthening of the regulatory framework for financial services and corporations laws generally as recommended by the ASICERT.

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Review of the pricing framework for electronic conveyancing services in NSW

1 October 2019

The most important issue for the ABA is that Australia adopts a nationally consistent approach to eConveyancing as it will drive competition, choice and price efficiency.

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Franchising Task Force Issues Paper – Response

20 September 2019

The ABA is committed to supporting an effective and fair regulatory framework in the franchising sector. The ABA supports the need to have input from franchisees on franchising policy and is open to assisting the Taskforce to understand the benefits of existing governance mechanisms such as Franchise Advisory Councils

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Treasury Consultation on the Digital Platforms Inquiry 2019

19 September 2019

The ABA acknowledges the breadth of the report and supports initiatives to improve privacy protections for banking customers. The ABA makes several points in this submission which warrant further review of recommendations 16-17 with respect to privacy, and also recommendations 20-21 with respect to unfair contract terms and unfair practices, and data portability.

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Review of the Intergovernmental Agreement for an Electronic Conveyancing National Law

19 September 2019

The ABA welcomes the IGA review and is in general, supportive of its findings, draft recommendations and the draft options for improvement.

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Consultation Paper 313 – Product Intervention Power and draft Regulatory Guide

7 August 2019

We acknowledge The Australian Securities and Investments Commission’s (ASIC) intention to provide ‘high level’ guidance, and to rely on the ordinary meaning of ‘significant detriment’. However, for the efficient implementation of this measure, maximum clarity around the meaning of this term is desirable.

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Enforceability of financial services industry codes

18 April 2019

Recommendation 1.15 should be implemented in a manner consistent with Commissioner Hayne’s clear intention to preserve the benefits and fundamental self-regulatory characteristics of financial sector codes.

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