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Submissions

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Consultation 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.

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Protecting Critical Infrastructure and Systems of National Significance

16 October 2020

The ABA strongly supports the Government’s desire to build on rather than duplicate existing regulation. A harmonised approach is critical to the implementation of these reforms in the banking industry. A single regulator having a clear mandate and a transparent system in place for regulatory co-ordination for banks - a model that may be relevant for other parts of the banking and financial services sector and other sectors.

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Proposed 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.

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APRA 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.

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Banking Amendment (Deposits) Bill 2020

10 July 2020

The ABA believes that deposits are currently protected and could not be bailed in during the resolution process of any ADI.

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APG 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

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ARS 115 Standardised measurement approach to operational risk

24 February 2020

The ABA asks APRA to consider the ARS 115 consistency with the accounting standard and consistency with current data consultation outcomes.

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Revisions 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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Financial Regulator Coordination and Information Sharing

24 January 2020

The ABA supports the codification of the expectation that where one regulator possesses information about an obvious and significant breach of laws administered by the other, the regulator should pass that information on. This will ensure early detection of misconduct and swifter enforcement action.

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Interest rate risk in the banking book

16 December 2019

The ABA supports the alignment of APS 117 with the Basel Committee on Banking Supervision interest rate risk in the banking book issued April 2016 where appropriate.

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