AFMA's view on policy issues are often conveyed through formal submissions. This list presents our public submissions, though we do deal with many issues that are not listed here. For queries about policy issues please contact us.

Date Title & Summary
 Topic Area Sent To
5 March 2012 Australia in the Asian Century

The submission welcomes the initiative of the Government in commissioning a White Paper on Australia in the Asian Century, and presents the opportunities for financial services that the Asian Century provides.

Other
 The Australia in the Asian Century Task Force
29 February 2012 ASIC CP 172 - Review of the EDR Jurisdiction over Complaints when Members Commence Debt Recovery Legal Proceedings

The submission, in response to a review of the external dispute resolution (EDR) regime, raises concerns about how aspects of the regime have been misused in practice.

Regulation
 ASIC
28 February 2012 Carbon Permit Auction Design

The submission makes recommendations on the design of the carbon permit auction process under an emission trading scheme.

Other
 Department of Climate Change and Energy Efficiency
20 February 2012 ASIC CP 168 - Australian Equity Market Structure: Further Proposals

The submission, in response to ASIC proposals on market structure issues including dark pools and high frequency trading, focuses on the cumulative burden of the proposals and calls for a return to a more structured and steady process of regulatory change.

Regulation
 ASIC
14 February 2012 Development of the Retail Corporate Bond Market - Streamlining Disclosure and Liability Requirements

The submission, in response to the Government's proposals to streamline disclosure and liability requirements for prospectuses for retail bond offers, supports the objective to develop a vibrant domestic corporate bond market in Australia.

Regulation
 Treasury
13 February 2012 Proposed Rules Implementing the "Volcker Rule"

The submission, on proposed rules in the US that will implement the "Volcker Rule", cautions against the potential extra-territorial effects of the proposed rules, which will have an impact on non-US foreign banks that have branches or banking subsidiaries in the US.

Regulation
 US Federal Reserve, Federal Deposit Insurance corporation, Office of the Comptroller of the Currency, Securities and Exchange Commission
13 February 2012 Carbon Floor Price - Surrender Charge for International Units

The submission makes recommendations on the technical mechanism for implementation of a floor price for international permits in the domestic market.

Other
 Department of Climate Change and Energy Efficiency
10 February 2012 Interim Report on the Tax Treatment of Losses

The submission, in response to consultation on options to reform the tax treatment of losses and black holes, agrees that there is benefit to more balanced tax loss rules.

Taxation
 Treasury
6 February 2012 ASIC CP 171 - Stregthening the Regulation of Research Report Providers

The submission, in response to ASIC proposals for research report providers to separate their business units as a strategy to manage conflicts of interest, notes that AFMA members do no produce commissioned research on financial products.

Regulation
 ASIC
3 February 2012 Handling and Use of Client Money in relation to Over-the-Counter Derivative Transactions

The submission supports the objective of proposed reforms of the client money rules in the Corporations Act in Connection with retail OTC derivatives, subject to appropriate scoping of the reforms.

Regulation
 Treasury
3 February 2012 Fringe Benefits Tax Reform (Living-Away-From-Home Benefits)

The submission raises concerns about the impact of announced changes to the living-away-from-home (LAFH) tax benefit rules on expatriate employees in the finance industry.

Taxation
 Treasury
27 January 2012 2012-13 Pre-Budget Submission

The submission presents a number of priority items for the Government's consideration, in its framing of the upcoming 2012-13 Budget.

Taxation
 Treasury
24 January 2012 EMIR Clearing Requirement - 'Intra-group Definition'

The submission to the European Commission raises concerns with the definition of 'intra-group' as it relates to proposed measures on OTC derivative transactions, central counterparties and trade repositories in the European Market Infrastructure Regulation (EMIR).

Regulation
 European Commission