The ABA seeks a workable structure for AUSTRAC levies that balances the need to deter and prevent money laundering, on the risk-based approach, with AUSTRAC's objective of recovering the cost of regulatory activities.
While the Australian Bankers’ Association agrees broadly with the comments submitted by the International Bankers Federation, it offers these comments concerning financial institutions in jurisdictions such as Australia that share a set of characteristics that make them so inhospitable to tax evasion by U.S. taxpayers as to render the application of Chapter 4 unnecessary and unjustifiable.
The Australian Bankers’ Association (ABA) noted that this is an important piece of legislation for our members and recognises that there have been significant changes to the drafting, but a number of the ABA’s concerns have not been addressed and there will be extensive changes required to comply with the new regime.
The Australian Bankers’ Association provided comment on this Exposure Draft to the International Accounting Standards Board. The ABA supports some of the ED’s proposals relating to defined benefit plans, however, we believe the proposed “net interest” approach will result in incomparable financial statements; is out of step with efforts to harmonise IFRS and US GAAP, and result in less meaningful information for investors and accounting, which is further from the underlying economic reality.
The Australian Bankers’ Association (ABA) understands the objective of the proposal to ensure that all regulatory capital instruments issued by banks be capable of absorbing losses in the event that a bank is unable to support itself in the private market. In achieving this objective it is fundamental that the subordination hierarchy for bank-issued instruments is respected.
The Australian Bankers’ Association (ABA) has provided this submission to the Australian Securities and Investments Commission on the Mortgage Exit Fees Consultation paper 135 (CP135).
The ABA’s response on CP 135 notes that there are both legal and market
competition factors that the ABA believes should be taken into account.