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Submissions

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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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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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National Housing Finance and Investment Corporation Investment Mandate Amendment (First Home Loan Deposit Scheme) Direction 2019

4 November 2019

The ABA welcomes any assistance to help first homebuyers to own their own home and supports the Government’s commitment to deliver the First Home Loan Deposit Scheme. Further, the ABA welcomes APRA’s letter to industry clarifying the capital treatment of the guarantee.

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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.

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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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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.

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