Supplementary submission to ASIC Consultation Paper 209: Update to RG 209 Credit Licensing: Responsible lending conduct
26 November 2019
The ABA strongly supports the retention of a principles-based approach to responsible lending through the legislative provisions contained in the NCCP Act, as well as in relation to relevant regulatory guidance, including in ASIC’s RG 209 and APRA’s APG 223 and APS 220.
Download PDFCapital treatment of mortgages under the First Home Loan Deposit Scheme
11 November 2019
The ABA welcomes further clarity on the capital treatment for guarantees under the Scheme. A clear understanding of the capital treatment is critical for an ADI’s mortgage product development and consequential approval under the scheme.
Download PDFRemoval of the exemption for funeral expenses policies
18 October 2019
The ABA fully supports the removal of the exemption for funeral expenses policies from the defintion of financial products.
Download PDFCorporations Amendment (Design and Distribution Obligations) Regulations 2019
11 October 2019
The ABA welcomes the exclusion from the requirement to provide a Target Market Determination (TMD) of credit provided wholly or predominantly for business purposes. In implementing this legislation, it is important that the principle of scalability be flexibly applied and that clear guidance be given on this by ASIC. We welcome the clarification around the... Read more »
Download PDFASIC Enforcement Review Taskforce
11 October 2019
The ABA supports stronger powers for ASIC and a strengthening of the regulatory framework for financial services and corporations laws generally as recommended by the ASICERT.
Download PDFReview of the pricing framework for electronic conveyancing services in NSW
1 October 2019
The most important issue for the ABA is that Australia adopts a nationally consistent approach to eConveyancing as it will drive competition, choice and price efficiency.
Download PDFFranchising Task Force Issues Paper – Response
20 September 2019
The ABA is committed to supporting an effective and fair regulatory framework in the franchising sector. The ABA supports the need to have input from franchisees on franchising policy and is open to assisting the Taskforce to understand the benefits of existing governance mechanisms such as Franchise Advisory Councils
Download PDFTreasury Consultation on the Digital Platforms Inquiry 2019
19 September 2019
The ABA acknowledges the breadth of the report and supports initiatives to improve privacy protections for banking customers. The ABA makes several points in this submission which warrant further review of recommendations 16-17 with respect to privacy, and also recommendations 20-21 with respect to unfair contract terms and unfair practices, and data portability.
Download PDFReview of the Intergovernmental Agreement for an Electronic Conveyancing National Law
19 September 2019
The ABA welcomes the IGA review and is in general, supportive of its findings, draft recommendations and the draft options for improvement.
Download PDFConsultation Paper 313 – Product Intervention Power and draft Regulatory Guide
7 August 2019
We acknowledge The Australian Securities and Investments Commission’s (ASIC) intention to provide ‘high level’ guidance, and to rely on the ordinary meaning of ‘significant detriment’. However, for the efficient implementation of this measure, maximum clarity around the meaning of this term is desirable.
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