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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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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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