Deferred Sales Model Exemptions
9 August 2021
The ABA supports the Government’s proposed regulations to exempt insurance products from the deferred sales model that provide high value and are well understood by consumers. This provides a more targeted approach to add-on insurance products subject to the deferred sales model and will address consumer harms and poor value identified by the Royal Commission without affecting the availability and accessibility of high value insurance products. However, the ABA considers there is further room to refine the proposed regulations in relation to business insurance.
Download PDFLoans impacted by COVID-19: APRA regulatory support
6 August 2021
The ABA considers that the part and full repayment moratoriums, offered as part of the ABA 2021 national support package, aligns with the regulatory approach provided for in draft Attachment E to assist banks in supporting customers through this period.
Download PDFBanking Code Review (2021)
6 August 2021
The ABA is planning to strengthen the small business section in this version of the Code by expanding the definition and increasing the number of small businesses able to access covenant light contracts from their bank
Download PDFABA InfoSec Standards – Position Paper
23 July 2021
Incorporating responses to Data Standards Body consultation: Decision Proposals 182. CDR Information Security Recommendations Ensuring that the appropriate technical standards for information security are put in place to enable the CDR is vital. These technical standards need to accommodate both an extension in scope for open banking, as well as setting the template for expansion of the CDR to other sectors of the economy. This paper makes the following recommendations: 1. Adopt FAPI 2.0 for future best practice 2. Ensure and Preserve Interoperability
Download PDFCDR Proposal for Purpose-based Consent
23 July 2021
The proposed solution put forward in DP-183 refers to a principle of ‘Purpose-based consent’. Purpose-Based Consents are a way to encode all of the required dimensions and granularity for a specific use case. Unfortunately, this specificity leads to a consequent loss in flexibility. DP-183 highlights read-only use cases which are not currently covered; however, the same principles and requirements are even stronger to enable read-write access.
Download PDFShared responsibility in drought support
21 July 2021
Banks in Australia have a strong history of helping agri-business customers through difficult times. Banks provide a range of services to help farming customers experiencing not only the effects of drought but also natural disasters or other circumstances outside their control. The ABA welcomes the Government's continued support regarding the existing provisions of in-drought support measures.
Download PDFUsing technology to hold meetings and sign and send documents
16 July 2021
The ABA supports legislation being technology neutral and facilitating innovation in how companies and businesses engage with shareholders and other stakeholders.
Download PDFDigital Identity Position Paper (Phase 2)
16 July 2021
ABA reiterates our view that there is significant potential economic benefit in the government’s digital identity initiative for consumers and businesses. ABA also reiterates that the ability of a government digital identity system to achieve wider adoption, and therefore realise the potential economic benefits of this government policy, will likely depend on factors such as clarity of legislative framework, flexibility to innovate and incentive to participate, security of protections for data and privacy, and clarity and effectiveness of governance arrangements.
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 PDFReview of the ePayments Code: further consultation (CP341)
2 July 2021
The ABA supports proposals to clarify the definition of a mistaken internet payment (MIP), Further work is needed to assess the case and benefits of the proposal to extend the ePC to small business. While the ABA supports modernising the Code, we consider the proposals about biometrics and virtual cards need further work. ABA also asks ASIC to consider a more fulsome modernisation of the Code.
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