Submission to the Payments System Review
29 January 2021
The ABA strongly supports continuing the self-regulatory arrangements within our regulatory architecture. The payments regulatory architecture should support innovation, as well as ensure the stability, and security of an expanded payments ecosystem. Innovation in payments should be considered through the lens of consumer and business end-users. These users rightly expect that when they make a payment, whether this is done through traditional channels or via a new app, their payments will be made in a timely, safe and secure way and their data will be secure.
Download PDFDigital Identity Legislation: consultation paper
18 December 2020
Banks are actively exploring digital identity initiatives and see the benefit of collaboration between government and industry. The interests of the Australian economy will be better served if there is flexibility to innovate and respond to the needs of consumers and businesses, instead of establishing a single government digital identity scheme. Government can also achieve genuine collaboration with industry without legislation.
Download PDFResponse to Senate Select Committee on Fintech and RegTech
17 December 2020
The ABA urges the development of an overarching strategy for data and information privacy to underpin the transition to a digital economy and provide a consistent framework for future reforms. Co-ordination will be critical to achieve the intended outcomes. The data economy has the real and exciting potential to generate jobs and opportunities for servicing the needs of all Australians. Technology and digital capability are the mechanisms by which banking will continue to develop.
Download PDFConsultation on the Data Availability and Transparency (DAT) Bill 2020
6 November 2020
The ABA supports the broad policy that public sector data should be able to be shared with appropriate safeguards if doing so is in the public interest, under the proposed regime (DAT regime). However, the ABA considers the Bill as drafted would significantly undermine Commonwealth regimes that have enabled effective business regulation in banking and other critical economic sectors. As such, the ABA strongly urges the Government to provide an exclusion for data that is covered by existing confidentiality provisions in regulatory regimes, such as section 56 of the APRA Act 1998, and consider alternative means of achieving this policy objective in relation to this class of data.
Download PDFCorporations Amendment (Virtual Meetings and Electronic Communications) Bill 2020
30 October 2020
We strongly welcome the Government’s proposal to make the electronic execution of company documents and virtual meetings reforms permanent for the benefit and convenience of customers and to improve efficiencies in the processing of critical documents. The ABA considers: • Deeds should be able to be created and signed electronically by companies and individuals. • Electronic signatures rather than wet signatures should be able to be used for a broader range of legal and business documents. • Remote witnessing should be legally valid.
Download PDFABA Commentary on Proposed Expansions to CDR Rules 2020
29 October 2020
The ABA does not support the proposed segmentation of banking data into high, medium, and low risk. The speed at which the Australian Competition and Consumer Commission (ACCC) intends to finalise the draft Rules is concerning, especially given risks which have been raised in the Privacy Impact Assessment (PIA). The ABA does not believe that it is possible for the ACCC to mitigate the risks raised in the PIA and concurrently resolve the questions and concerns raised in this submission by December 2020. The ABA is particularly concerned with negative impacts the speed of implementation will have on smaller banks. The ABA is also concerned that consumers may be overwhelmed with the level of complexity in the proposed Rules which may make them less likely to participate in the CDR. Trust in the security of the CDR is paramount to its success. The ABA urges the ACCC to reconsider the intention to finalise these rules by December 2020 and seeks a meeting with the ACCC to discuss the concerns raised in this submission
Download PDFProtecting Critical Infrastructure and Systems of National Significance
16 October 2020
The ABA strongly supports the Government’s desire to build on rather than duplicate existing regulation. A harmonised approach is critical to the implementation of these reforms in the banking industry. A single regulator having a clear mandate and a transparent system in place for regulatory co-ordination for banks - a model that may be relevant for other parts of the banking and financial services sector and other sectors.
Download PDFAusPayNet application for revocation of authorisation A91497 and A91498 and substitution of AA1000495
6 May 2020
The ABA supports the AusPayNet application for re-authorisation. The ABA considers the Issuers and Acquirers Community (IAC) framework provides opportunities for coordination, self-regulation and policy setting which delivers important public benefits.
Download PDFARS 115 Standardised measurement approach to operational risk
24 February 2020
The ABA asks APRA to consider the ARS 115 consistency with the accounting standard and consistency with current data consultation outcomes.
Download PDF