While the ABA supports ‘unquestionably strong’ capital ratios, the ABA agrees with APRA that this embedded conservatism makes it more difficult and/or costly for Australian ADIs to access international capital markets if these Australian differences are not well understood, particularly during times of market dislocation.
The ABA is cognisant of the size and complexity of the task APRA has in finalising and calibrating a number of significant reforms to the Australian prudential framework. The ABA looks forward to continued dialogue to ensure an appropriate implementation of the capital framework for Australian ADIs.
This consultation is a step forward in improving the risk sensitivity, consistency and operational process of some aspects of the market risk framework. However, certain aspects of the framework remain excessively onerous, unduly complex and unrepresentative of the actual risk intended to be mitigated in smaller markets such as Australia.
The ABA welcomes the APRA discussion paper which includes proposed revisions to the capital framework, as well as other changes to better align the framework to risks, including in relation to housing lending.
The ABA welcomes APRA’s steps to strengthen the industry’s cyber resilience and also supports measures that will require all regulated entities to lift their cyber security capabilities.
The Australian Banking Association (ABA) appreciates the opportunity to provide APRA with comments on the Discussion Paper: Leverage ratio requirement for authorised deposit-taking institutions
The ABA recommends that the draft legislative instrument be amended so that a ‘small ADI’ would be defined as having less than or equal to $30 billion total resident assets rather than the current definition of having less than or equal to $10 billion total resident assets (on a three-year average).
The ABA provided comments to Treasury regarding the Exposure Draft of the Financial Sector Legislation Amendment (Crisis Resolution Powers and Other Measures) Bill 2017 and the associated draft Explanatory Memorandum.
Open Banking will allow customers, at their request, to share their personal information with other financial institutions to allow them to find a better deal on expenses such as electricity bills, telecommunications and other items.
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