Submissions 2011

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ABA submission on Inquiry into the National Consumer Credit Protection Amendment (Credit Card and Home Loans) Bill 2011
23 May 2011
The ABA provided two submissions to the House of Representatives Standing Committee on Economics on the exposure draft National Consumer Credit Protection Amendment (Credit Cards and Home Loans) Bill 2011. The ABA and its member banks have significant concerns with the Government’s policy on credit cards and home loans key fact sheets.
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ABA submission to the Reserve Bank’s Review of Card Surcharging
24 Apr 2011
The Australian Bankers’ Association (ABA) has been considering possible approaches to balancing the twin goals of putting downward pressure on merchant surcharges but, in doing so, not imposing large compliance costs on merchants, banks and schemes, or risking unintended consequences through price regulation. Banks have an interest in this issue because even though banks have no control over whether merchants impose surcharges, or the level of those surcharges, research shows that many consumers believe card surcharges are actually imposed by banks.
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Australian Bankers’ Association submission on Hedge Accounting ED/2010/13
9 Mar 2011
The Australian Bankers’ Association (ABA) provided general thoughts and commented on the specific questions raised by the International Accounting Standards Board Exposure Draft. The ABA supports the Board’s efforts to improve the current hedge accounting Requirements because the current requirements under IAS 39 are too restrictive and result in accounting outcomes that don’t reflect the economic relationships established by an entity’s risk management strategies.
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Exposure Draft National Consumer Credit Protection Amendment Regulations 2001
28 Feb 2011
The Australian Bankers’ Association (ABA) provided this submission to Treasury regarding the ban on exit fees. The ABA has always argued that these fees represent legitimate costs. The impact of not being to recover those costs will fall proportionately more heavily on smaller lenders than larger ones.
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Australian Bankers’ Association Submission on Sound Practices for the Management and Supervision of Operational Risk – Supervisory Guidelines for the Advanced Measurement Approaches
25 Feb 2011
The Australian Bankers’ Association provided comment to the Bank of International Settlements on their Consultation paper Sound Practices for the Management and Supervision of Operational Risk – Supervisory Guidelines for the Advance Measurement Approaches consultation paper.
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Australian Bankers’ Association Submission on Pillar 3 Disclosure Requirements for Remuneration – Consultative Document
25 Feb 2011
The Australian Bankers’ Association provided comment to the Bank of International Settlements on the Committee’s Consultative Document – Pillar 3 Disclosure Requirements for Remuneration, released in December 2010. The ABA supports the underlying objective of promoting effective market discipline through improving the quality and comparability of remuneration disclosures. However, we believe that the design of many of the proposed Pillar 3 disclosure requirements will not allow market participants to meaningfully assess the quality of compensation practices and their alignment to a firm’s risk management framework and long-term financial soundness.
Submission to Parliamentary Joint Committee on Corporations and Financial Services Access for Small and Medium Business to Finance
11 Feb 2011
The Australian Bankers’ Association (ABA) noted that small businesses have had a tough trading period throughout the global financial crisis and are still dealing with its impacts. Weaker trading conditions can undermine small business balance sheets due to reduced revenues. Unfortunately, some small businesses have experienced cash flow problems, and in some cases, this has caused banks to decline loan applications because of the businesses’ reduced ability to repay their loans.

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