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Phase 1.5 AML/CTF Rules and Guidance

8 June 2021

The ABA strongly supports the objectives of the AML/CTF regime. It also strongly supports that the obligations be simplified, streamlined and clarified, and the regulatory burden reduced where possible. While we are supportive of these amendments overall, the ABA seeks clarification on aspects of the draft Rules and Guidance.

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Regulator Performance Guide

2 June 2021

The ABA considers that the review of the existing Regulator Performance Guide is timely. It is critical to ensure that regulation of the financial system does not inhibit the ability of financial firms to serve the Australian population or grow the economy. The ABA supports the Government’s proposal to transition towards a more flexible and principles-based approach to regulator performance. We have developed our response with a focus on providing constructive suggestions to improve the potential scope and application of the three principles that are proposed with regard to financial regulation Continuous improvement and building trust Risk-based and data-driven Collaboration and engagement

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Opt-Out Joint Account Data Sharing Model

26 May 2021

Whilst the ABA supports the principle of a simple CDR, we question the ability to develop a ‘one-size-fits-all-sectors’ approach to joint accounts. The ABA supports retaining the current opt-in approach. The proposed opt-out approach is not supported on the basis that it undermines the foundational principle of the CDR, which is informed consent. We are of the view that it is not feasible to nominate an industry preferred option at this point.

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Inquiry into mobile payment and digital wallet financial services

25 May 2021

While existing inquiries or reform initiatives touch on these policy issues, the issues are not confined to any single legislative framework or the responsibility of any single agency. They need a holistic assessment of potential policy solutions and their impact on consumers and the economy as a whole. A siloed approach may fail to consider the impact of specific recommendations or reforms on the Government’s policy to foster Australia’s digital economy and retain digital talent. As such, the ABA recommends robust coordination on policy and implementation that sees the oversight of mobile payment and digital wallet as a key plank of Australia’s digital economy.

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APRA’s approach to new entrant ADIs

30 April 2021

The ABA welcomes an updated approach to new entrant ADIs focusing on sustainability. Providing pathways for restricted entry promotes competition through innovation amongst ADIs. The ABA agrees with APRA that an important balance needs to be made between supporting entities to both enter and thrive in the banking sector, while ensuring financial stability and protecting the interests of depositors.

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APRA: A more flexible and resilient capital framework for ADIs

1 April 2021

The ABA recommends that the final policy settings accurately reflect the proven resilience of banks and the needs of the Australian economy. The ABA also expects further calibration to be undertaken to ensure there is no increase to the overall level of capital in the banking system, considers that the proposed application of a non-standard treatment to interest-only mortgages with terms greater than five years is unduly punitive, considers that the proposed capital allocation to New Zealand exposures at Level 2 is set at a conservative level that is not commensurate with the level of risk ABA members also feel consideration should be given to increasing the default level of the proposed CCyB, it considers that the required IT updates makes the 1 January 2023 commencement date challenging, encourages APRA to promptly update its 2015 International capital comparison study and some of APRA’s current proposals may amplify volatility without necessarily improving the measurement of risk.

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Modernising Business Communications

3 March 2021

The ABA welcomes the Government’s establishment of the Deregulation Taskforce (Taskforce). The proposed reforms to modernise business communications have the potential to reduce business costs and reflect the way Australian consumers and businesses prefer to manage their financial affairs today. The ABA particularly welcomes the Taskforce’s whole-of-economy approach by working to improve technology neutrality across Commonwealth laws, and importantly - partnering with states and territories to explore opportunities to achieve national consistency.

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The bankruptcy system and the impacts of coronavirus

21 February 2021

The current economic circumstances have not changed the views that we expressed in response to the proposal to shorten the default period for bankruptcy that was contained in the Bankruptcy Amendment (Enterprise Incentives) Bill 2017.

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Critical Infrastructure Bill 2020

12 February 2021

The ABA has recommended a number of changes be made to the Bill enshrining verbal assurances already provided by the Department of Home Affairs. The ABA also proposes early consultation with industry to ensure time and resources for compliance, and to ensure guidance as to what information the government may require from critical infrastructure entities and the nature of information sharing between government and critical infrastructure sectors.

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Treasury consultation on licensing debt management firms

12 February 2021

The ABA supports the Government’s proposal to licence debt management and credit repair firms. We believe that all Australians should be afforded consistent consumer protections, no matter which credit or financial services provider they choose.

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