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Nature Market Repair Bill – Exposure Draft

3 March 2023

Proposed text: ABA submission to the exposure draft of the Nature Repair Market Bill. The submission makes short high-level constructive comments about the need for more thinking around the fundamental drivers that will underpin a successful nature repair market.

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Payment Times Reporting Act

3 March 2023

The ABA supports the policy objective that large businesses pay small businesses on time. Banks have taken a range of steps to support small business customers throughout the COVID-19 pandemic and following recent major natural disasters. As a relatively new reporting regime, the ABA considers there is room to improve the scheme to ensure greater efficiency while maintaining or improving its effectiveness.

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ASIC Investigation and Enforcement

28 February 2023

ABA notes that one of the considerations for ASIC ought to be the deployment of the best combination of enforcement tools that would bring about early resolution of matters in a way that would promote customer confidence. Unresolved issues which extend for many months are unhelpful to customer confidence. Additionally, extended resolution times can cause uncertainty within the industry as it awaits an outcome. We suggest EUs and Infringement Notices are particularly useful because they not only punish poor practices, but they also deliver speedier improvements to business practice and customer outcomes.

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Digital platform regulatory reform

24 February 2023

ABA’s submission focuses on issues that are of interest to the banking industry and our customers. In particular, ABA supports the ACCC’s recommendations for digital platforms to be subject to targeted measures including about scams.

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Climate-related Financial Disclosures

17 February 2023

The ABA supports the introduction of mandatory climate-related financial disclosures aligned with the International Sustainability Standards Board. This will provide banks and business with the certainty they need to manage their climate risks and to grasp the opportunities from the new green industrial revolution. The submission highlights the need for collaboration on data gaps, safe harbour provisions or alternative legal measures, and appropriate phasing.

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National Reconstruction Fund: Corporation Bill

8 February 2023

The Australian Banking Association (ABA) broadly supports the intention of the National Reconstruction Fund Corporation Bill 2022 and the National Reconstruction Fund (Fund), which is expected to support and diversify Australia’s emerging industry sectors but has some concerns in relation to the Fund’s design and implementation, including the proposed priority areas, scope of the investment mandate and how these matters may impact on the crowding out of the private sector market that is otherwise willing and able to invest in these areas. It is noted that banks already invest in many of the priority areas proposed by the Government and investments in these areas would be better suited towards the beginning of their lifecycle where it is more difficult for banks to manage the risk profile. The ABA recommends it being a requirement of the investment mandate to consult with traditional private sector participants before making an investment by the Fund, such as via a panel of financiers. Government should assess the commerciality of each prospective investment and refer it to the private sector where it is sensible to do so from the perspective of return and/or risk appetite.

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Payments strategic plan

6 February 2023

ABA proposes the strategic plan in its first iteration prioritises: 1) implementing a payments licence and revising the Payment Systems (Regulation) Act 1998; 2) responding to scams: taking a cross-sectoral approach to disrupting scams, protecting consumers and providing educations and awareness; 3) digital identity adoption; and 4) migrating from legacy to modern payments infrastructure.

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National Energy Performance Strategy

3 February 2023

The Australian Banking Association (ABA) supports the intent of the National Energy Performance Strategy. The ABA considers that enhancements to building codes and regulations, coupled with decarbonising the grid, can be an effective way to support improvements to energy performance. We also advocate for the provision of rebates, tax incentives and subsidies to support the adoption of energy efficiency technologies, particularly in relation to individuals from low-income households who may not have the capacity to fund energy efficiency upgrades.

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National Reconstruction Fund: consultation paper

1 February 2023

The Australian Banking Association (ABA) supports the intent of the National Energy Performance Strategy. The ABA considers that enhancements to building codes and regulations, coupled with decarbonising the grid, can be an effective way to support improvements to energy performance. We also advocate for the provision of rebates, tax incentives and subsidies to support the adoption of energy efficiency technologies, particularly in relation to individuals from low-income households who may not have the capacity to fund energy efficiency upgrades.

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ADI centralised publication update and consultation

31 January 2023

ABA supports APRA’s decision to limit the first stage of ADI data publication to metrics which are aligned with bank Pillar 3 disclosures, while also noting there are some metrics which are not wholly consistent with these bank disclosures. Given the limited number metrics to be published, in contrast to the original proposal, ABA is comfortable with immediate publication on a quarterly frequency from June 2023.

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