Submissions 2010

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Australian Bankers’ Association Submission on ED/2010/9 Leases
16 Dec 2010
The Australian Bankers’ Association provided comment on the Leases Exposure Draft to the International Accounting Standards Board.
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The Australian Bankers’ Association submission on Discussion Paper: Cost Recovery for AUSTRAC’s regulatory functions
10 Dec 2010
The ABA seeks a workable structure for AUSTRAC levies that balances the need to deter and prevent money laundering, on the risk-based approach, with AUSTRAC's objective of recovering the cost of regulatory activities.
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Australian Bankers’ Association submission on Notice 2010-60 to the Internal Revenue Service, Washington
1 Nov 2010
While the Australian Bankers’ Association agrees broadly with the comments submitted by the International Bankers Federation, it offers these comments concerning financial institutions in jurisdictions such as Australia that share a set of characteristics that make them so inhospitable to tax evasion by U.S. taxpayers as to render the application of Chapter 4 unnecessary and unjustifiable.
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Australian Bankers’ Association submission to Minister for Innovation, Industry, Science and Research on Tax Laws Amendment (Research and Development) Bill 2010
6 Oct 2010
The Australian Bankers’ Association (ABA) noted that this is an important piece of legislation for our members and recognises that there have been significant changes to the drafting, but a number of the ABA’s concerns have not been addressed and there will be extensive changes required to comply with the new regime.
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Australian Bankers’ Association Submission on ED/2010/3 Defined Benefits Plans
9 Sep 2010
The Australian Bankers’ Association provided comment on this Exposure Draft to the International Accounting Standards Board. The ABA supports some of the ED’s proposals relating to defined benefit plans, however, we believe the proposed “net interest” approach will result in incomparable financial statements; is out of step with efforts to harmonise IFRS and US GAAP, and result in less meaningful information for investors and accounting, which is further from the underlying economic reality.
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Australian Bankers’ Association Submission on Basel Committee proposal to ensure the loss absorbency of regulatory capital at the point of non-viability
1 Sep 2010
The Australian Bankers’ Association (ABA) understands the objective of the proposal to ensure that all regulatory capital instruments issued by banks be capable of absorbing losses in the event that a bank is unable to support itself in the private market. In achieving this objective it is fundamental that the subordination hierarchy for bank-issued instruments is respected.
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Australian Bankers’ Association Submission on Countercyclical capital buffer proposals
1 Sep 2010
The Australian Bankers’ Association provided comment to the Basel Committee on Banking Supervision’s consultative document on Countercyclical capital buffer proposal.
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Mortgage Early Exit Fees Consultation Paper 135 (CP 135)
2 Aug 2010
The Australian Bankers’ Association (ABA) has provided this submission to the Australian Securities and Investments Commission on the Mortgage Exit Fees Consultation paper 135 (CP135). The ABA’s response on CP 135 notes that there are both legal and market competition factors that the ABA believes should be taken into account.
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ABA submission on the National Credit Reform Green Paper
2 Aug 2010
The ABA have provided this submission to the Corporations and Financial Services Division of the The Treasury. The ABA notes that the matters canvassed in the Green Paper are very significant, particularly the chapters of the Paper that deal with small business, investment and credit card lending. The ABA has a real concern to ensure that the Green Paper is not the culmination of the government’s consultation process. Rather, it is the forerunner to a more focused empirical research project than can examine and evaluate the wider economic and market implications of any intended regulatory intervention.
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ABA submission on Exposure Draft of Australian Privacy Principles and Companion Guide
2 Aug 2010
The ABA has provided this submission to the Senate Finance and Public Administration Committee on the exposure draft of the Australian Privacy Principles (APPs) and Companion Guide. The APPs are a welcome development towards a more seamless and nationally focused Australia privacy regime. The submission provides ABA comment on the details of the exposure draft.

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