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Consultation 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.

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Consultation on responsible lending (RG209)

20 May 2019

The ABA is concerned that a move away from a principles based approach will negatively affect competition.

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Australian 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.

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Prudential 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

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ACCC 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.

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Enforceability 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.

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AFCA 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.

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APRA 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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IGA eConveyancing Paper

10 April 2019

While the Issues Paper comprehensively considers the impact of eConveyancing from an industry and government perspective, greater consideration should be given to the consumer outcome.

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Banking System Reform (Separation of Banks) Bill 2019

9 April 2019

The ABA does not support this Bill and has concerns with the drastic regulatory intervention it proposes. The industry’s existing reform program will be more efficient, less costly and less disruptive to the economy and community.

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