The ABA lodged its submission with the BCBS on the Consultative Document Reducing variation in credit risk-weighted assets - constraints on the use of internal model approaches. The ABA supports a simple and comparable capital framework that retains appropriate risk sensitivity.
The ABA provided the BCBS with comments on the Consultative Document: Pillar 3 disclosure requirements - consolidated and enhanced framework. The ABA is supportive of the proposed enhancements and the consolidation of all existing and prospective BCBS disclosure requirements into the Pillar 3 framework.
The ABA lodged a submission with Treasury on the GST treatment of digital currency.
The submission addresses three key aspects of the discussion paper: 1) The desired policy outcome, 2) Identifying and characterising digital currencies, and 3) The alternative approaches to the GST treatment of digital currencies.
The ABA responded to the BCBS CD: Standardised Measurement Approach for operational risk and in responding to the specific questions raised, also provided the Committee with additional feedback for consideration.
The ABA provided comments to AUSTRAC on the Industry Contribution for 2016-17 and suggested they be read in conjunction with the submissions provided on 23 July 2014, 24 October 2014, 17 December 2014, and 26 August 2015.
The ABA provided APRA with its comments on the Discussion Paper: Margining and risk mitigation for non-centrally cleared derivatives. While generally supporting the comprehensive submissions by the Australian Financial Markets Association and International Swaps and Derivatives Association, the ABA and members have some specific comments on CPS 226 which are of particular importance to members.