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2021 Credit Reporting Code consultation

11 August 2021

The ABA provides the following recommendations and observations: 1. Promises to pay vs. financial hardship arrangements: We are concerned that ARCA’s proposal to define financial hardship arrangements (FHAs) is overly prescriptive and conflicts with elements of the National Consumer Credit Protection Act 2009 (NCCP). 2. Backdating the start of a financial hardship arrangement: The ABA does not support the approach allowing backdating of a financial hardship arrangement. 3. Payment test & catch-up periods: The ABA is supportive of the proposal for a payment test period or catch-up period to be treated as a financial hardship arrangement where the arrangement immediately follows, and is in response to, an earlier financial hardship arrangement. 4. Treatment of joint accounts where abuse is present: We are supportive of the interim proposal that ARCA has proposed to take extra care of customers experiencing family and domestic violence (FDV).

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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.

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Loans 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.

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Banking 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

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ABA 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

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CDR 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.

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Shared 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.

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Using 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.

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Digital 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.

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Reporting 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.

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