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Automated Decision Making and AI Regulation

20 May 2022

Australian banks are using new technologies to increase efficiency and to provide new and more responsive services to customers. We propose the government focus on: simplifying or rationalising existing legislation that impact on the use of AI and ADM, in preference to new specific AI regulations; any regulatory intervention including setting best practice guidance should build on existing best practices and harmonise with sector specific regulation; and review and amend legislation to be neutral as to whether a human or technology is used to make decisions or conduct a process.

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Electronic Conveyancing National Law

11 March 2022

The Australian Banking Association (ABA) continues to support efforts to accelerate the adoption of electronic mortgages for the convenience of consumers and the associated economic benefits. The ABA and its members have actively contributed to the development of e-conveyancing since its infancy as well as interoperability and the associated reforms. The banking industry is supportive of progressing the Electronic Conveyancing National Law to implement interoperability, with further consultation to consider in detail the issues that ABA and other stakeholders have raised. This 2-step process is a pragmatic response to the complexity of the reform, and the need to balance certainty of the reforms with addressing important issues that stakeholders have raised.

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Critical Infrastructure Protection Bill

1 March 2022

The ABA welcomes the steps the Government is taking to work with critical industries to enhance industries’ operational and cyber resilience. ABA members already cooperate with the relevant Government agencies and with the Council of Financial Regulators (CFR) on cyber security matters and we look forward to strengthening those partnerships. ABA has identified a number of implementation issues or issues that are likely to require further legislative amendment. ABA proposes a two-year statutory review of the significant amendments introduced to the Security of Critical Infrastructure Act 2018.

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Australia’s cyber security regulations and incentives

27 August 2021

The ABA sees an important role for government in coordinating messaging and cyber security uplift efforts across stakeholder groups and sectors, and setting clear expectations of what entities should do to protect themselves and their customers. The ABA acknowledges that there is a difficult but important balance to be struck between, on the one hand, economy wide, consistent cyber security regulatory requirements that improve the nation’s cyber risk position and, on the other hand, more specific or targeted measures which need to respond to specific risks and/or levels of risk. Further clarity will also be required for entities that may be indirectly subject to SOCI Act requirements, and for entities that may move in and out of the SOCI Act regime. The ABA seeks further information about the legal form that the governance standards would take and what legal standing (if any) the standards would have. The ABA asks for clarity on the interaction between the proposed standards and other regulatory regimes.

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ABA InfoSec Standards – Position Paper

23 July 2021

Incorporating responses to Data Standards Body consultation: Decision Proposals 182. CDR Information Security Recommendations Ensuring that the appropriate technical standards for information security are put in place to enable the CDR is vital. These technical standards need to accommodate both an extension in scope for open banking, as well as setting the template for expansion of the CDR to other sectors of the economy. This paper makes the following recommendations: 1. Adopt FAPI 2.0 for future best practice 2. Ensure and Preserve Interoperability

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Australia as a Technology and Financial Centre – Issues Paper

30 June 2021

The ABA welcomes the G20 support for FATF action on the regulation and oversight of virtual assets and virtual asset service providers. The ABA supports Australia’s adoption of FATF Standards to support responsible innovation across the financial services sector by regulating and supervising virtual asset activities and related service providers in order to mitigate the associated money laundering and terrorist financing risks.

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Opt-Out Joint Account Data Sharing Model

26 May 2021

Whilst the ABA supports the principle of a simple CDR, we question the ability to develop a ‘one-size-fits-all-sectors’ approach to joint accounts. The ABA supports retaining the current opt-in approach. The proposed opt-out approach is not supported on the basis that it undermines the foundational principle of the CDR, which is informed consent. We are of the view that it is not feasible to nominate an industry preferred option at this point.

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Inquiry into mobile payment and digital wallet financial services

25 May 2021

While existing inquiries or reform initiatives touch on these policy issues, the issues are not confined to any single legislative framework or the responsibility of any single agency. They need a holistic assessment of potential policy solutions and their impact on consumers and the economy as a whole. A siloed approach may fail to consider the impact of specific recommendations or reforms on the Government’s policy to foster Australia’s digital economy and retain digital talent. As such, the ABA recommends robust coordination on policy and implementation that sees the oversight of mobile payment and digital wallet as a key plank of Australia’s digital economy.

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Modernising Business Communications

3 March 2021

The ABA welcomes the Government’s establishment of the Deregulation Taskforce (Taskforce). The proposed reforms to modernise business communications have the potential to reduce business costs and reflect the way Australian consumers and businesses prefer to manage their financial affairs today. The ABA particularly welcomes the Taskforce’s whole-of-economy approach by working to improve technology neutrality across Commonwealth laws, and importantly - partnering with states and territories to explore opportunities to achieve national consistency.

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Submission to the Payments System Review

29 January 2021

The ABA strongly supports continuing the self-regulatory arrangements within our regulatory architecture. The payments regulatory architecture should support innovation, as well as ensure the stability, and security of an expanded payments ecosystem. Innovation in payments should be considered through the lens of consumer and business end-users. These users rightly expect that when they make a payment, whether this is done through traditional channels or via a new app, their payments will be made in a timely, safe and secure way and their data will be secure.

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