Submissions

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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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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)

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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 »

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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.

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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

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