Submissions

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.