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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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Housing Legislative Package

11 January 2023

The ABA supports the Housing Legislative Package and the establishment of the Housing Australia Future Fund as a mechanism to provide a sustainable funding source to support and increase the development of social and affordable housing. The Housing Legislative Package should also assist in alleviating critical affordable housing needs for frontline workers, older women on low incomes, family and domestic violence survivors and First Nations communities. Australian banks have worked closely with non-profits and Government over recent years to support the social housing sector. The ABA and banks offer to work closely with the Government and other key stakeholders during the development of the investment mandate for Housing Australia to ensure it aligns with the previous recommendations of the Statutory Review of the Operation of the NHFIC Act 2018, including those relating to ‘crowding-in’ financiers. The ABA also recommends that Government consider expanding the current appointments of the National Housing Supply and Affordability Council to include members with a strong banking or lending background.

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Property Law Act Review

15 December 2022

The Australian Banking Association (ABA) welcomes the opportunity to provide further feedback on the Queensland Government’s consultation on the Property Law Bill 2022 and Property Law Regulation 2023. The ABA supports some of the revisions to the latest draft of the Bill but remains of the view that flood history data should be contained within the seller’s disclosure statement, particularly in light of repeated flooding events across Australia. It also has concerns with directing prospective buyers to the FloodCheck Queensland and Australian Flood Risk Information portals, where information may be incomplete or incorrect, to understand the flooding history of a property.

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Review of the Reserve Bank of Australia

8 November 2022

The Australian Banking Association (‘ABA’) welcomes the opportunity to make this submission to the Review of the Reserve Bank of Australia. The ABA notes the significant role of Australia’s central bank in delivering good economic outcomes for the nation. We support the ongoing independence of the Reserve Bank of Australia in executing its mandate. The ABA’s responses to the panel’s questions in the Issues Paper (15 September 2022) raises these key points: - We consider the three objectives to be appropriate, noting there may be an opportunity to update the expression of the objectives in Section 10(2) of the Reserve Bank Act (1959). - We see opportunities for Reserve Bank of Australia (‘the RBA’ or ‘the Bank’) to augment its communications to explain the complexities underlying the decisions as well as greater explanation of the trade-offs made between the Bank’s objectives. - We see the independence of the RBA as critical to ensuring a well-functioning economy.

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Global agreement on Corporate Taxation

1 November 2022

Australian Banks support the intent of this global agreement to address the risks and leverage the opportunities arising from the digitalisation of the global and domestic economy. The ABA recommends that where possible, Australia’s implementation of the proposes measures should align with existing reporting and administrative requirements, and should be consistent with international approaches to ensure a streamlined and effective implementation.

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ASIC industry funding model

28 October 2022

The ABA considers the ASIC industry funding model is broadly meeting its objectives. The funding model promotes equitable outcomes across the financial services industry and for the community, by ensuring that entities that create the need for regulation bear the costs rather than taxpayers. However, there is scope to increase the transparency of the ASIC funding and improve some aspects of the reporting mechanisms.

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Property Tax (First Home Buyer Choice) Bill 2022

26 October 2022

The ABA supports the Property Tax (First Home Buyer Choice) Bill 2022 in its current form before NSW Parliament.

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CDR Action Initiation

24 October 2022

The ABA notes the rollout of write access should be done safely, with the protection of customer data being a key principle. We also recommend that there should be a strategic assessment ahead of declaring any actions, and that payment initiation will need to align with the broader payments work.

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Public Disclosure Requirements for ADIs (APS 330)

7 October 2022

The ABA acknowledges APRA’s objective to align disclosures with international standards and is supportive of the objectives to promote transparency, improve comparability for prudential metrics across ADIs, and enhance proportionality by removing disclosure requirements for smaller ADIs. The ABA provides the feedback contained in this letter for APRA’s consideration. However, industry expects to raise additional observations and points for clarification as part of the transition to BCBS-based standards.

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Tasmanian Land Titles Amendment Bill

29 September 2022

The Australian Banking Association (ABA) welcomes the Department of Natural Resources and Environment Tasmania’s engagement with industry regarding the proposed amendment to the Land Titles Act 1980. The ABA and its members are broadly supportive of the proposed amendment but make two observations for the Land Titles Office’s consideration.

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