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Farm Debt Mediation (QLD)

25 March 2022

Farm Debt Mediation (FDM) is widely acknowledged as a successful way for the farmer and the financier to resolve matters relating to farm business debts and, in many cases, is a preferred alternative to court. Most importantly, the FDM process provides an additional avenue for farmers in financial difficulty to either re-establish and maintain their viability or exit the industry with dignity. The ABA welcomes the review’s consideration of opportunities to enhance the Act and align with legislation in other states where possible.

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APRA: Capital Framework Revisions Draft Guidance

14 March 2022

The ABA continues to support a revised capital framework that strengthens the financial resilience of the industry, embeds the industry’s unquestionably strong level of capital and provides for greater flexibility in periods of stress. ABA member banks are actively working towards the implementation of APRA’s revised capital framework. Considerable work still remains in both defining and implementing the framework based on the practice guides issued as well as implementing related changes to regulatory reporting, modifications to Pillar 3 and international comparability studies, and updates to related standards.

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Electronic Conveyancing National Law

11 March 2022

The Australian Banking Association (ABA) continues to support efforts to accelerate the adoption of electronic mortgages for the convenience of consumers and the associated economic benefits. The ABA and its members have actively contributed to the development of e-conveyancing since its infancy as well as interoperability and the associated reforms. The banking industry is supportive of progressing the Electronic Conveyancing National Law to implement interoperability, with further consultation to consider in detail the issues that ABA and other stakeholders have raised. This 2-step process is a pragmatic response to the complexity of the reform, and the need to balance certainty of the reforms with addressing important issues that stakeholders have raised.

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AG: Bankruptcy system options paper

8 March 2022

The ABA provides feedback to the Attorney-General’s Department on the Bankruptcy system options paper and encourages the Government to consider these changes in the context of the broad suite of reforms made or proposed in recent years that potentially change the consequences of insolvency for companies and bankruptcy for individuals. This includes small business insolvency reforms, changes to schemes of arrangement and the review of the safe harbour regime. The ABA also highlights the need for Government and policymakers to consider how these reforms may impact the flow of credit to small businesses and the effect of this on commercial activity with the aim of striking the right balance between creditors and debtors.

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ALRC Financial Services Legislation, Interim Report A

4 March 2022

The ABA provides feedback to the Australian Law Reform Commission (ALRC) on the Financial Services Legislation, Interim Report A. In addition to specific feedback provided in this submission on the questions and proposals put forward by the ALRC in Interim Report A, the ABA welcomes further consultation and engagement on the following four issues as the ALRC inquiry continues. The first being the potential to create a single Act to regulate financial services in Australia and significantly reduce the complexity that exists within the current regulatory framework.  The second concerns the alignment of definitions with those in other legislative instruments to create confidence and certainty for all stakeholders including consumers.  The third issue highlights the need for further consultation regarding the potential impact of ‘outcomes-based’ disclosure increasing the complexity of information provided to consumers.  Lastly, the ABA highlights that implications for emerging markets and products be considered so that laws are drafted in a technology-neutral manner and, are drafted sufficiently broadly so that their application is not limited to existing products and services.

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Proposed changes to quarterly ADI statistical publications

3 March 2022

The ABA supports changes to the templates of quarterly ADI statistics due to the associated changes with APRA Reporting Standards 220, 223 and 230. The ABA recommends proactively delaying first publication of the new quarterly ADI statistics beyond the June 14 date to ascertain and correct any possibly data quality issues resulting from the implementation of the new reporting standards.

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Critical Infrastructure Protection Bill

1 March 2022

The ABA welcomes the steps the Government is taking to work with critical industries to enhance industries’ operational and cyber resilience. ABA members already cooperate with the relevant Government agencies and with the Council of Financial Regulators (CFR) on cyber security matters and we look forward to strengthening those partnerships. ABA has identified a number of implementation issues or issues that are likely to require further legislative amendment. ABA proposes a two-year statutory review of the significant amendments introduced to the Security of Critical Infrastructure Act 2018.

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Supporting business adoption of electronic invoicing (BER)

25 February 2022

The ABA provides feedback to Treasury regarding the proposal to introduce a Business EInvoicing Right to accelerate business adoption of Peppol international eProcurement framework. The ABA strongly supports initiatives aimed at increasing business awareness and accelerating the adoption of eInvoicing; however, considers it premature to mandate a BER at this point in time.

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Macroprudential and APS 220

25 February 2022

Increasing the macroprudential policy options available to APRA and transparency regarding when and how they may be used, should assist with enhancing the financial stability and resilience of the Australian economy. The ABA is supportive of these measures which offer a useful complement to the resilience provided by Australia’s well capitalised and well managed banks. In developing and implementing market interventions, such as macroprudential policies, it is vitally important that unintended consequences, regulatory burden and competition distortions are minimised. As such, and considering the system wide consequences of macroprudential interventions, the ABA strongly recommends APRA incorporates and imbeds processes to ensure early and close engagement with the banking industry before any macroprudential policies are implemented. Additional recommendations and points for clarification are included in the ABA’s submission to APRA.

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IBFed Climate-related Financial Risks

16 February 2022

This is an IBFed submission to the BCBS’s consultation on the draft Principles for the effective management and supervision of climate-related financial risks. The ABA is a signatory to this submission.

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