Submissions

Filter Content

Clear all
APRA’s revisions to the capital framework for ADIs

23 September 2019

An earlier implementation date for the revised operational risk capital requirements will be difficult and should be optional.

Download PDF
Financial institutions supervisory levy methodology discussion paper submission

13 September 2019

The ABA supports appropriate cost reflective funding of APRA. An adequately resourced regulator will ensure its regulatory mandate is undertaken in a timely and effective way.

Download PDF
APRA Consultations on margining and risk mitigation for non-centrally cleared derivatives

28 August 2019

The ABA supports APRA’s amendments to Prudential Standard CPS 226 Margining and risk mitigation for non-centrally cleared derivatives (CPS 226)

Download PDF
APRA consultation on APS 220 Credit Risk Management

5 July 2019

The ABA welcomes the timely review of APS 220 to incorporate the new developments in credit risk management practices, including the new accounting standards and the Basel Committee supervisory guidance on sound credit risk practices. The ABA agrees that effective management of credit risk is a critical component of a comprehensive approach to risk management... Read more »

Download PDF
Consultation on revisions to prudential practice guide APG 223 residential mortgage lending

21 June 2019

The ABA welcomes APRA’s revision of the current buffer and floor limits set in December 2014.

Download PDF
Prudential Practice Guide CPG 234 Information Security

17 May 2019

The ABA’s has specific comments on the following chapters: Third parties and related parties Implementation of controls Internal audit Attachment B: Training and awareness Attachment C: Identity and access

Download PDF
APRA Capability Review

12 April 2019

The ABA supports the Government decision to undertake regular capability reviews of financial regulators as recommended in the Royal Commission Final Report.

Download PDF
International Capital Framework Comparability

12 November 2018

While the ABA supports ‘unquestionably strong’ capital ratios, the ABA agrees with APRA that this embedded conservatism makes it more difficult and/or costly for Australian ADIs to access international capital markets if these Australian differences are not well understood, particularly during times of market dislocation.

Download PDF
APRA Discussion Paper: Revisions to the related entities framework for ADIs

4 October 2018

The ABA is cognisant of the size and complexity of the task APRA has in finalising and calibrating a number of significant reforms to the Australian prudential framework. The ABA looks forward to continued dialogue to ensure an appropriate implementation of the capital framework for Australian ADIs.

Download PDF
Revisions to the minimum capital requirements for market risk

20 June 2018

This consultation is a step forward in improving the risk sensitivity, consistency and operational process of some aspects of the market risk framework. However, certain aspects of the framework remain excessively onerous, unduly complex and unrepresentative of the actual risk intended to be mitigated in smaller markets such as Australia.

Download PDF