Appropriate Lending Approach to Small Business
16 October 2023
The provision of credit to small business is critical to the success of the economy and the prosperity of Australians, and ABA members are committed to the success of Australia’s small business sector. The ABA acknowledges AFCA’s work in developing a public approach to small business lending and understands that AFCA’s intention in publishing its approach to small business is to aid small business borrowers and lenders in understanding how AFCA currently approaches its determinations. However, there is a likelihood that the degree of prescription AFCA adopts in the draft SME Approach may have this effect and introduce a level of detail that goes beyond existing requirements under laws, standards, and codes. We urge AFCA to adopt a principles-based approach based on established principles, standards, and requirements in small business lending, such as the BCOP, to ensure that lending to small businesses is not restricted and is consistent with existing requirements.
Download PDFCONSULTATION ON DRAFT VERSION 9 OF THE REGISTRAR’S REQUIREMENTS
10 October 2023
The ABA has concerns with the proposed Registrar’s Requirements and their impact on the Memorandum of Common Provisions (MCPs). We respectfully request that LUV reconsider the adoption of the proposed Registrar’s Requirement 19. This change phases out of the use of already registered and long-established MCPs across industry, with little policy justification. The ABA maintains... Read more »
Download PDFISSB Consultation on agenda priorities
31 August 2023
ABA submission to the ISSB Consultation on Agenda Priorities.
Download PDFClimate-related financial disclosures, second-round consultation
21 July 2023
The ABA supports the introduction of mandatory climate-related financial disclosures aligned with the ISSB, and we feel that the proposed model generally strikes an appropriate balance. The submission makes key points across six areas: phased approach, reporting content, reporting location, assurance, continuous disclosure and the modified liability approach.
Download PDFABA submission to ACCC retail deposits inquiry
17 July 2023
The ABA’s submission to the ACCC’s Retail Deposits Inquiry 2023. Australian banks continue to provide a competitive, dynamic, and innovative marketplace for deposits. Banks are also cognisant of the variety of uses for deposit accounts and strive to provide products and services that meet the needs of customers.
Download PDFSetting, tracking and achieving Australia’s emissions reduction targets
14 July 2023
ABA submission to the Climate Change Authority’s consultation on “Setting, tracking and achieving Australia’s emissions reduction targets”. The submission highlights the significance of data availability towards tracking and achieving Australia’s emissions reduction targets.
Download PDFProposal to legislate and reform Chapter 75 Exemptions (December 2021)
14 June 2023
14 June 2023 The ABA responds to the Department of Home Affairs and AUSTRAC on a consultation proposing to legislate and reform section 75 of the Anti-Money Laundering and Counter-Terrorism Financing Rules 2007.
Download PDFConsultation Paper – Electronic Creation and Execution of Documents
2 June 2023
The ABA Submission is supportive of the Landgate’s efforts to enable the creation and execution of documents in electronic form. The ABA provides answers to the specific questions in the Landgate consultation paper.
Download PDFABA submission on APRA Interest Rate Risk in the Banking Book workshop
2 June 2023
The Australian Banking Association (ABA) welcomes Australia Prudential Regulation Authority’s (APRA) ongoing and constructive engagement, and the opportunity to respond to the policy options on the revised draft Prudential Standard APS 117 Capital Adequacy: Interest Rate Risk in the Banking Book (APS 117), which were presented to industry on 18 May 2023.
Download PDFTreasury Laws Amendment (2023 Measures No. 1) Bill 2023 – Franked distributions funded by capital raisings
2 May 2023
The ABA submission to the Senate Economic Committee, the submission addresses the importance of certainty regarding capital raises and distributions to banks.
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