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ELNOs Interoperability Pricing Issues Paper July 2022

12 August 2022

The ABA and its members remain supportive of the realisation of a functioning interoperable e-conveyancing market. A functioning interoperable e-conveyancing market should benefit subscribers and other stakeholders, including everyday Australians. The ABA and its members encourage IPART to consider the implications of its recommendations on all e-conveyancing market participants, paying particular attention to the potential cost consequences of subscribers, some of which have little negotiating power.

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Farm Debt Mediation Better Practice Guide Consultation

19 July 2022

The ABA acknowledges the challenges experienced to date in implementing uniform farm debt mediation (FDM) legislation nationally however, despite these challenges, the ABA position remains that farmers across Australia should have access to the same safeguards and support regardless of their postcode.

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AASB request reply on ISSB IFRS Submission

15 July 2022

The ABA supports a global approach to the development of sustainability disclosure standards through the ISSB as the global body to issue the standards. Further, the establishment of a global baseline is critical a coordinated approach be developed which will avoid fragmentation in reporting obligations. To this end we support the efforts of the ISSB in establishing a working group to enhance compatibility between global baseline and jurisdictional initiatives.

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ISSB Sustainability-related Financial Information climate disclosures

15 July 2022

ABA's position on the IFRS Foundations ISSB proposed financial disclosures. The Australian Banking Association (ABA) welcomes the opportunity to provide feedback to the International Sustainability Standards Board (ISSB) on the Exposure Draft on IFRS S1 General Requirements for Disclosure of Sustainability-related Financial Information ([Draft] IFRS S1) and Exposure Draft IFRS S2 Climate-related Disclosures ([Draft] IFRS S2).   We support a global approach to the development of sustainability disclosure standards through the ISSB as the global body to issue the standards. Further, we support the climate-first approach adopted by the ISSB. We see great value in the ISSB issuing a forward workplan (or consulting on a proposed forward workplan) to enable entities to prepare for future sustainability disclosure requirements.

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Australian Data Strategy

30 June 2022

The Australian Banking Association (ABA) welcomes the development of a unified strategy around the use of public and private data to drive economic, health and social outcomes. We are optimistic that all Australians will benefit from a coordinated government approach. ABA members encourage government to streamline their collection of data from banks, and encourage government to work with industry when developing future policies around data security and privacy and governance related to Artificial Intelligence.

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Directions for Data Collections

24 June 2022

The Australian Banking Association has responded to the Australian Prudential Regulation Authority’s (APRA) Directions for Data Collections and its associated five-year road map. The outline of APRA’s vision and the reasoning underpinning its strategy has allowed banks to start planning for and resourcing what is to be a major regulatory change, requiring significant investment. ABA members are now looking for the next level of detail on the future data collection, so they can start their own projects to ensure delivering to APRA’s timetables in the most efficient manner possible.

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Revisions to the ADI Capital Framework

6 June 2022

The Australian Banking Association has provided feedback on the interim reporting standards and parallel run expectations for the ADI capital framework. This submission provides feedback on reporting timelines and dates, level of consolidation and scope of submissions as well as definitional questions relating to specific reporting standards

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Pragmatic implementation of APG 110, APG 112 and APG 113

31 May 2022

To assist consistency of implementation across the industry, the Australian Banking Association has developed industry position on a range of aspects regarding the implementation of APRA’s revised capital framework.

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APS 117 Compliance Costs

24 May 2022

The ABA welcomes APRA’s ongoing engagement regarding the implementation of the revised APS 117 and provides the attached estimate of the associated compliance costs.

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Automated Decision Making and AI Regulation

20 May 2022

Australian banks are using new technologies to increase efficiency and to provide new and more responsive services to customers. We propose the government focus on: simplifying or rationalising existing legislation that impact on the use of AI and ADM, in preference to new specific AI regulations; any regulatory intervention including setting best practice guidance should build on existing best practices and harmonise with sector specific regulation; and review and amend legislation to be neutral as to whether a human or technology is used to make decisions or conduct a process.

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