APRA consultation on APS 220 Credit Risk Management
5 July 2019
The ABA welcomes the timely review of APS 220 to incorporate the new developments in credit risk management practices, including the new accounting standards and the Basel Committee supervisory guidance on sound credit risk practices. The ABA agrees that effective management of credit risk is a critical component of a comprehensive approach to risk management... Read more »
Download PDFComments on the Working Draft of the Consumer Data Standards
21 June 2019
ABA’s submission to Data 61 on Consumer Data Rights Standards 0.9.3 highlighted the need for a number of important functional and security requirements to be embedded in the regime.
Download PDFConsultation on revisions to prudential practice guide APG 223 residential mortgage lending
21 June 2019
The ABA welcomes APRA’s revision of the current buffer and floor limits set in December 2014.
Download PDFConsultation on responsible lending (RG209)
20 May 2019
The ABA is concerned that a move away from a principles based approach will negatively affect competition.
Download PDFAustralian Law Reform Commission Corporate Crime Inquiry
17 May 2019
It is important that any consideration of the liability of individuals for corporate misconduct take account of the various avenues pursuant to which individuals might be personally liable for corporate misconduct under the law as it stands.
Download PDFPrudential Practice Guide CPG 234 Information Security
17 May 2019
The ABA’s has specific comments on the following chapters: Third parties and related parties Implementation of controls Internal audit Attachment B: Training and awareness Attachment C: Identity and access
Download PDFACCC Draft Consumer Data Rules
10 May 2019
The ACCC’s draft Rules provide a good foundation for the implementation of open banking, however there are a number of areas that have not been addressed in the draft Rules or which require further guidance.
Download PDFEnforceability of financial services industry codes
18 April 2019
Recommendation 1.15 should be implemented in a manner consistent with Commissioner Hayne’s clear intention to preserve the benefits and fundamental self-regulatory characteristics of financial sector codes.
Download PDFAFCA Rules Consultation – Legacy Disputes
15 April 2019
This is an important first step in enabling AFCA to deal with legacy complaints about conduct by financial firms dating back to 1 January 2008 that have not been previously considered and fall outside the period allowed under AFCA’s existing jurisdiction.
Download PDFAPRA Capability Review
12 April 2019
The ABA supports the Government decision to undertake regular capability reviews of financial regulators as recommended in the Royal Commission Final Report.
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