Public Disclosure Requirements for ADIs (APS 330)
7 October 2022
The ABA acknowledges APRA’s objective to align disclosures with international standards and is supportive of the objectives to promote transparency, improve comparability for prudential metrics across ADIs, and enhance proportionality by removing disclosure requirements for smaller ADIs. The ABA provides the feedback contained in this letter for APRA’s consideration. However, industry expects to raise additional observations and points for clarification as part of the transition to BCBS-based standards.
Download PDFAPRA: Capital Framework Revisions Draft Guidance
14 March 2022
The ABA continues to support a revised capital framework that strengthens the financial resilience of the industry, embeds the industry’s unquestionably strong level of capital and provides for greater flexibility in periods of stress. ABA member banks are actively working towards the implementation of APRA’s revised capital framework. Considerable work still remains in both defining and implementing the framework based on the practice guides issued as well as implementing related changes to regulatory reporting, modifications to Pillar 3 and international comparability studies, and updates to related standards.
Download PDFMacroprudential and APS 220
25 February 2022
Increasing the macroprudential policy options available to APRA and transparency regarding when and how they may be used, should assist with enhancing the financial stability and resilience of the Australian economy. The ABA is supportive of these measures which offer a useful complement to the resilience provided by Australia’s well capitalised and well managed banks. In developing and implementing market interventions, such as macroprudential policies, it is vitally important that unintended consequences, regulatory burden and competition distortions are minimised. As such, and considering the system wide consequences of macroprudential interventions, the ABA strongly recommends APRA incorporates and imbeds processes to ensure early and close engagement with the banking industry before any macroprudential policies are implemented. Additional recommendations and points for clarification are included in the ABA’s submission to APRA.
Download PDFReporting Standard ARS 720.1
8 September 2021
We request that the new ARS 720.1 come into effect on 1 March 2022 so that both ARF 220.0 and ARF 720.1 will be first prepared on the new standards consistently for the period ended 31 March 2022.
Download PDFBank Capital Reforms: Update
20 August 2021
We support a revised capital framework that strengthens the financial resilience of the industry, embeds unquestionably strong levels of capital and also provides for greater flexibility in periods of stress. We recommend that APRA: • replace the parallel run with targeted quantitative impact surveys (QIS) • delay the implementation of the standardised approach for foundation and advanced internal ratings based (FIRB and AIRB) authorised deposit-taking institutions (ADIs) • reduce the regulatory reporting burden on ADIs for March 2023, and • delay the implementation of new Pillar 3 changes to 2024.
Download PDFContingent Liquidity: Proposed Guidance
20 August 2021
The ABA supports maintaining an excess reserve of eligible assets for contingent funding to ensure stability during periods of stress. However, we have concerns regarding the revised requirements as currently proposed by APRA. In particular: 1. It is well-above international standards 2. It is proposed to include offshore operations 3. It is to apply at all times 4. An implementation pathway has not been proposed
Download PDFReporting Standard ARS 220.0 Credit Exposures and Provisions (APRA)
6 July 2021
The ABA and members are supportive of APRA’s move to data collection based on a concept-dimension data model. ABA members broadly support the approach APRA has outlined in their letter of June 8. The collective view of ABA members is that a successful implementation will result from sufficient time being given to develop a full taxonomy, and that this is finalised well in advance of the first submission date so banks can build the infrastructure to support the data model. ABA members have concerns with the overlap of two new reporting requirements (the tactical solution and the incremental collections), the granular level of detail required for the strategic solution (especially for the lower risk portfolios) and the timing by which each reporting needs to be provided.
Download PDFAPRA: A more flexible and resilient capital framework for ADIs
1 April 2021
The ABA recommends that the final policy settings accurately reflect the proven resilience of banks and the needs of the Australian economy. The ABA also expects further calibration to be undertaken to ensure there is no increase to the overall level of capital in the banking system, considers that the proposed application of a non-standard treatment to interest-only mortgages with terms greater than five years is unduly punitive, considers that the proposed capital allocation to New Zealand exposures at Level 2 is set at a conservative level that is not commensurate with the level of risk ABA members also feel consideration should be given to increasing the default level of the proposed CCyB, it considers that the required IT updates makes the 1 January 2023 commencement date challenging, encourages APRA to promptly update its 2015 International capital comparison study and some of APRA’s current proposals may amplify volatility without necessarily improving the measurement of risk.
Download PDFCritical Infrastructure Bill 2020
12 February 2021
The ABA has recommended a number of changes be made to the Bill enshrining verbal assurances already provided by the Department of Home Affairs. The ABA also proposes early consultation with industry to ensure time and resources for compliance, and to ensure guidance as to what information the government may require from critical infrastructure entities and the nature of information sharing between government and critical infrastructure sectors.
Download PDFConsultation 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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