Critical 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.
Download PDFProtecting 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.
Download PDFProposed 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.
Download PDFAPRA 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.
Download PDFBanking 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.
Download PDFAPG 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
Download PDFARS 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.
Download PDFRevisions 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.
Download PDFFinancial 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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