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Submissions

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Revisions to APS 111 Capital Adequacy: Measurement of Capital

14 February 2020

The ABA supports APRA’s review of the capital framework but asks for further consideration of investment in regulated subsidiaries.

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ACCC CDR consultation on how to best facilitate participation of third party service providers

7 February 2020

The ABA supports the inclusion of TPSPs within the CDR regime. TPSPs could play an important role in the efficient and cost-effective provision of services to consumers. The entry of TPSPs, with appropriate governance and consumer protections, will enable the development of a richer and more vibrant ecosystem.

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Corporate Criminal Responsibility Discussion Paper (DP 87) November 2019

7 February 2020

The ABA supports a principled approach to policy making on Commonwealth criminal responsibility. Such an approach stands to enhance confidence in the regulatory framework by providing consistent, predictable treatment of conduct across the regulatory landscape.

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Financial Regulator Coordination and Information Sharing

24 January 2020

The ABA supports the codification of the expectation that where one regulator possesses information about an obvious and significant breach of laws administered by the other, the regulator should pass that information on. This will ensure early detection of misconduct and swifter enforcement action.

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OAIC Public Interest Determinations on International Money Transfers

24 January 2020

The applications seek new PIDs to permit ANZ - along with other authorised-deposit taking institutionswithin the meaning of the Banking Act 1959 (ADIs); and the RBA to disclose the personal information ofa beneficiary of an IMT to an overseas financial institution when processing an IMT, without breachingthe Australian Privacy Principles (APPs). The ABA strongly supports these two applications and urges the OAIC to issue new PIDs which would replace existing PIDs concerning IMTs that are due to sunset on 25 February 2020

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Response to the Select Committee on FinTech and RegTech

24 December 2019

The ABA agrees that capital and funding, tax, skills and talent, culture and regulation are key factors that determine Australia’s competitive position to attract and maintain investment in technology. However, the ABA respectfully requests to also consider how Australia should best manage data in the emerging digital economy.

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Interest rate risk in the banking book

16 December 2019

The ABA supports the alignment of APS 117 with the Basel Committee on Banking Supervision interest rate risk in the banking book issued April 2016 where appropriate.

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Draft Consumer Data Right Privacy Safeguard Guidelines Consultation

27 November 2019

The ABA recommends that the PS GL undergo a second consultation twelve months after the launch of the CDR regime., and the ABA recommends that the OAIC institutes a process for annual review.

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Update to RG 209 Credit Licensing: Responsible lending conduct

26 November 2019

The ABA supports ASIC finalising this review and releasing updated regulatory guidance as soon as possible to provide clarity and assist credit licensees comply with their responsible lending obligations.

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Supplementary submission to ASIC Consultation Paper 209: Update to RG 209 Credit Licensing: Responsible lending conduct

26 November 2019

The ABA strongly supports the retention of a principles-based approach to responsible lending through the legislative provisions contained in the NCCP Act, as well as in relation to relevant regulatory guidance, including in ASIC’s RG 209 and APRA’s APG 223 and APS 220.

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