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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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Review of the Privacy (Credit Report) Code 2014

11 February 2022

The ABA generally considers that the CR Code works well to meet the competing objectives of privacy versus economic effectiveness.

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BCCC Priorities for 2022-23

8 February 2022

The ABA provides input to the Banking Code Compliance Committee (BCCC) consultation on its 2022-23 compliance priorities. In addition to its response on the six consultation questions, the ABA acknowledges the critical role the BCCC plays in both monitoring and enforcing banking sector compliance with the Banking Code of Practice and identifying best practice for banks to help achieve compliance in the best interests of customers. The ABA also acknowledges the BCCC submission to the Banking Code Triennial Review and looks forward to working closely as the ABA leads the development of an updated Code.

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AASB ITC 48 Extended External Reporting

7 February 2022

This submission responds to the Australian Accounting Standards Board consultation on extended external reporting (ITC 48.)

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CP354 Simple Hardship Arrangements

1 February 2022

The ABA requests confirmation from ASIC that a temporary financial hardship arrangement agreed under the Credit Reporting Code does not require a credit provider to send a ‘rejection notice’ under section 72(4)(b) of the National Credit Code. Once ASIC provides this confirmation, we consider that there is no real need for the continuation of the simple arrangement exemption in its current form.

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Improving the technology neutrality of Treasury portfolio laws

13 December 2021

The ABA remains very supportive of the Treasury’s ongoing efforts to improve the technology neutrality of the Treasury portfolio and look forward to further engagement on this, and subsequent, tranches of legislative change. Industry’s main comments regard allowing: • (under National Credit Code (NCC)) the ‘publish and notify’ and ‘in any other way agreed to’ methods of communications which are permitted under the Corporations Act; • more than one address to be used at any given time, which may be appropriate depending on the type of communications; and, • communications via secure portals instead of an email address, as securely housing certain notifications and communications within the credit providers (CP) information system, where it can be retrieved by customers after appropriate authentication, better balances the need for accessibility, security and technology neutrality.

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