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Submissions

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APRA’s revisions to the capital framework for ADIs

23 September 2019

An earlier implementation date for the revised operational risk capital requirements will be difficult and should be optional.

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Franchising Task Force Issues Paper – Response

20 September 2019

The ABA is committed to supporting an effective and fair regulatory framework in the franchising sector. The ABA supports the need to have input from franchisees on franchising policy and is open to assisting the Taskforce to understand the benefits of existing governance mechanisms such as Franchise Advisory Councils

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Treasury Consultation on the Digital Platforms Inquiry 2019

19 September 2019

The ABA acknowledges the breadth of the report and supports initiatives to improve privacy protections for banking customers. The ABA makes several points in this submission which warrant further review of recommendations 16-17 with respect to privacy, and also recommendations 20-21 with respect to unfair contract terms and unfair practices, and data portability.

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Review of the Intergovernmental Agreement for an Electronic Conveyancing National Law

19 September 2019

The ABA welcomes the IGA review and is in general, supportive of its findings, draft recommendations and the draft options for improvement.

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Financial institutions supervisory levy methodology discussion paper submission

13 September 2019

The ABA supports appropriate cost reflective funding of APRA. An adequately resourced regulator will ensure its regulatory mandate is undertaken in a timely and effective way.

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The Banking Executive Accountability Regime – Consultation on Product Responsibility

30 August 2019

The ABA endorses recommendation 1.17 of the Financial Services Royal Commission and APRA’s core objective of heightened and clarified end to end accountability among senior executives for an ADI’s products.

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APRA Consultations on margining and risk mitigation for non-centrally cleared derivatives

28 August 2019

The ABA supports APRA’s amendments to Prudential Standard CPS 226 Margining and risk mitigation for non-centrally cleared derivatives (CPS 226)

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Economy-wide Cash Payment Limit

12 August 2019

The Australian Banking Association (ABA) supports the Government’s introduction of an economy-wide cash payment limit to businesses for goods and services. Having a taxation system that is robust and one that meets community expectations is vital and we recognise the importance of this initiative to the integrity of our tax system.

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Consultation Paper 313 – Product Intervention Power and draft Regulatory Guide

7 August 2019

We acknowledge The Australian Securities and Investments Commission’s (ASIC) intention to provide ‘high level’ guidance, and to rely on the ordinary meaning of ‘significant detriment’. However, for the efficient implementation of this measure, maximum clarity around the meaning of this term is desirable.

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Open Banking designation instrument consultation (2nd round)

11 July 2019

Banking will be the first sector to apply the Consumer Data Right and the ABA supports the participation of more sectors over time to achieve an economy-wide open data regime.

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