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Model Participation Rules – ARNECC Consultation Draft Version 6

2 March 2020

The proposed amendments to the MPR are significant and the ABA is strongly opposed to Draft Version 6 of the MPR in their current form. The ABA is not aware of any instance of identity fraud in the electronic e-conveyancing system that would warrant such significant and costly changes.

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ARS 115 Standardised measurement approach to operational risk

24 February 2020

The ABA asks APRA to consider the ARS 115 consistency with the accounting standard and consistency with current data consultation outcomes.

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Senate Economics Committee Inquiry into the Australian Business Growth Fund Bill 2019 [Provisions]

17 February 2020

The ABA strongly supports the Government’s initiative to help small businesses grow by coinvesting with banks to establish this Australian Business Growth Fund. The Fund is designed to provide equity finance to qualifying businesses across a range of industries and locations.

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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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