Submissions - 2019

Date Title & Summary Topic Area Sent to
23-Dec-2019

Select Senate Committee on Financial Technology and Regulatory Technology

AFMA lodged a submission to the Committee highlighting the role of the Offshore Banking Unit regime in fostering the retention of Fintech firms in Australia.

Taxation Select Senate Committee on Financial Technology and Regulatory Technology
19-Dec-2019

Request for Guidance on matters associated with IBOR Transition

Letter from the IBOR Transformation Working Group seeking guidance from the Counsel of Financial Regulators on the supervisory expectation regarding conduct matters associated with the transition from LIBOR to RFRs. While this letter focuses on the challenges facing banks, other Australian financial institutions may be facing similar challenges.

Other Council of Financial Regulators (CoFR)
12-Dec-2019

Anti-Money Laundering and Counter-Terrorism Financing and Other Legislation Amendment Bill 2019

AFMA made a submission supporting the Bill and highlighting some areas of ambiguity/uncertainty that could be addressed by further legislative amendment prior to the Bill being passed.

Regulation Senate Legal and Constitutional Affairs Committee
08-Dec-2019

Banking, Finance and Insurance Award 2020‚ Annualised Wage Arrangements

AFMA made a submission to the Fair Work Commission seeking to find efficiencies and avoid the need for timesheets in the Annualised Wage arrangements for well remunerated staff.

Regulation Fair Work Commission
05-Dec-2019

Interest Rate Risk in the Banking Book for ADIs

AFMA comments on APRA's proposals in relation to the draft changes for Prudential Standard APS 117 Capital Adequacy: Interest Rate Risk in the Banking Book.

Regulation APRA
02-Dec-2019

ASX 24 Bond Futures Roll Consultation

AFMA response to the review by ASX of the Bond Futures Roll market structures. AFMA sought opportunities for improvements that will support the integrity and growth of the market and create savings for investors. AFMA also supported the changes to the Bills contracts, and encourages ASX to continue to review its products and rules to find market efficiencies.

Regulation ASX
27-Nov-2019

Review of the AUSTRAC Industry Contribution Levy Arrangements Issues Paper

An AFMA submission re. the AUSTRAC Industry Contribution Levy Arrangements Independent

Regulation Acacia CRE Pty Ltd
12-Nov-2019

COGATI Proposed Access Model - Discussion Paper

An AFMA submission to the AEMC on a discussion paper regarding COGATI proposed access model. We reiterated our comments made in our response to the April consultation paper. In previous submissions, and in several submissions by individual AFMA members, our key concern relates to the potential detrimental effects of the proposals on financial market liquidity. Furthermore, given that the proposed access model represents such fundamental reform if implemented, we believe the AEMC should consider implementation timing which is commensurate with the significance of the proposed change, and a detailed cost-benefit analysis of the change before a decision on implementation is made.

Regulation AEMC
31-Oct-2019

FG002 Financial Planners and Advisers Code of Ethics 2019 and Guidance

AFMA comments on the Financial Planners and Advisers Code of Ethics 2019 (Code) and FG002 Financial Planners and Advisers Code of Ethics 2019 Guidance (Guidance) as mechanisms to lift standards of professionalism across the industry.

Regulation FASEA Standards Authority
31-Oct-2019

Australia's 2020 Cyber Security Strategy

AFMA's feedback in response to the development of Australia's 2020 Cyber Security Strategy.

Regulation Department of Home Affairs - Cyber Security Policy Division
24-Oct-2019

APRA Discussion Paper: Strengthening prudential requirements for remuneration

AFMA welcomes the opportunity to make comment on APRA's proposals in relation to the draft prudential requirements for remuneration.

Regulation APRA
14-Oct-2019

Exposure Draft Consultation on Search Warrants, Access to Telecommunications Intercept Material, Lic

AFMA welcomes the opportunity to comment on the Treasury ASIC Enforcement Review Taskforce's Exposure Draft on Search Warrants, Access to Telecommunications Intercept Material, Licensing and Banning Orders.

Regulation The Treasury
04-Oct-2019

CP 322 Product intervention: OTC binary options and CFDs

AFMA comments on ASIC's proposals to exercise its product intervention power in Pt 7.9A of the Corporations Act to make certain market-wide product intervention orders relating to the issue and distribution of over-the-counter (OTC) binary options and contracts for difference (CFDs) to retail clients

Regulation ASIC
11-Sep-2019

Consultation on Amendments to Margin Requirements

AFMA comments on the consultation on Amendments to Margin Requirements set out to all APRA regulated institutions other than private health insurers.

Regulation APRA
09-Sep-2019

Consultation Paper 319: Securities lending by agents and substantial holding disclosure

AFMA welcomes the opportunity to comment on Consultation Paper 319: Securities lending by agents and substantial holding disclosure, noting that AFMA's membership includes many firms who participate in providing prime brokerage and agent securities lending services.

Regulation ASIC
30-Aug-2019

APRA Banking Executive Accountability Regime Consultation on Product Responsibility

AFMA comments on APRA's BEAR Consultation on Product Responsibility.

Regulation APRA
23-Aug-2019

ASIC CP 315 - Foreign financial services providers

AFMA responds to ASIC consultation paper 315 - Foreign Financial Service Providers.

Regulation ASIC
16-Aug-2019

Market making arrangements in the NEM - draft determination

An AFMA submission to the AEMC on a draft determination regarding market making arrangements in the NEM. AFMA is supportive of the AEMC's draft determination not to make a draft rule to introduce additional market making schemes in the national electricity market. We note also that the Commission is looking to work with relevant market bodies (including AFMA) to firstly, improve the transparency of the over-the-counter (OTC) market, and secondly, enhance the AER's powers to monitor market liquidity.

Regulation AEMC
16-Aug-2019

Consultation Paper 314: Market Integrity Rules for Technological and Operational Resilience

AFMA welcomes the opportunity to comment on Consultation Paper CP 314 Market Integrity Rules for Technological and Operational Resilience, having long been an active participant in the development of technological and operational aspects of the financial markets.

Regulation ASIC
12-Aug-2019

Australian Debt Capital Markets Management and Practice

AFMA members appreciate the opportunity to discuss Australian debt capital market (DCM) activities and practices with ASIC.

Regulation ASIC
09-Aug-2019

COAGATI Access Reform - Directions Paper

An AFMA submission to the AEMC on a directions paper regarding COGATI implementation - Access and Charging. We reiterated our comments made in our response to the April consultation paper. The introduction of dynamic regional pricing represents significant reform which has been presented as a solution without due consideration of costs and benefits of its implementation or of alternative solutions, and more detailed analysis of costs and benefits is desirable before major implementation decisions are made. It also introduces basis risk for generators who enter into hedging contracts based on the regional reference price, however may receive a different dynamic regional price.

Regulation AEMC
05-Aug-2019

CP 313 Product Intervention Power

AFMA comments on Consultation Paper 313 Product Intervention Power, which sets out proposals for regulatory guidance on the product intervention provisions in the Corporations Act flowing from the Treasury Laws Amendment (Design and Distribution Obligations and Product Intervention Act) 2019 amendments.

Regulation ASIC
17-Jul-2019

ASIC CP 312 Stub equity in control transactions

AFMA comments on ASIC Consultation Paper 312 - Stub equity in control transactions

Regulation ASIC
12-Jul-2019

Consultation on Pre-Cessation Issues for LIBOR and Certain other Interbank Offered Rates

AFMA welcomes the opportunity to make comment on the consultation concerning Pre-Cessation Issues for LIBOR and Certain other Interbank Offered Rates.

Regulation ISDA
28-Jun-2019

Guidance Note 20 Equity Derivatives Consultation - Supplementary Information

Supplementary information for AFMA's submission to the consultation on Guidance Note 20 - Equity Derivatives.

Regulation Takeovers Panel Secretariat
27-Jun-2019

AUSTRAC Industry Contribution 2019-20 - Stakeholder Consultation Paper

A submission in relation to AUSTRAC’s proposed charging model for the 2019/20 Industry Contribution.

Regulation AUSTRAC
17-Jun-2019

APRA Consultation on Proposed ARS 722.0 ABS/RBA Derivatives Data Collection

AFMA welcomes the opportunity to make comment on APRA's proposals in relation to the draft Reporting Standard 722.0 ABS/RBA Derivatives.

Regulation APRA
11-Jun-2019

ASIC Report 605 Allocations in equity raising transactions

The members of AFMA have given careful consideration to the best practices provided in ASIC Report 605: Allocations in equity raising transactions.

Regulation ASIC
31-May-2019

Guidance Note 20 Equity Derivatives Consultation

AFMA welcomes the review of Guidance Note 20 Equity Derivatives as an opportunity to increase the clarity of guidance and thereby better serve companies, bidders and the market.

Regulation Takeovers Panel Secretariat
23-May-2019

National Electricity Amendment (Short Term Forward Market) Rule 2019

An AFMA submission to the AEMC on a consultation paper regarding a suggested Short Term Forward Market. We believe that the majority of AFMA's energy market members are yet to be convinced that the benefits of an AEMO operated short term forward market as proposed would be outweighed by the costs that would necessarily need to be incurred.

Regulation AEMC
17-May-2019

CPG 234 Information Security

AFMA welcomes the opportunity to comment on APRA's consultation on Prudential Practice Guide CPG 234 Information Security.

Regulation APRA
10-May-2019

Consumer Data Right Rules Exposure Draft

AFMA welcomes the opportunity to provide comments in response to ACCC's Consumer Data Right Rules Exposure Draft consultation.

Association ACCC
06-May-2019

Proposed changes to Guidance Note 1 and Guidance Note 10 relating to business continuity and cyber r

AFMA welcomes the opportunity to provide comment on ASX's consultation paper in relation to guidance changes for clearing and settlement members relating to business continuity and cyber resilience.

Regulation ASX
02-May-2019

Consultation on Corporations Amendment (National Guarantee Fund Payments) Regulations 2019

AFMA responds to the consultation on the draft Corporations Amendment (National Guarantee Fund Payments) Regulations 2019.

Regulation The Treasury
30-Apr-2019

BEAR Variable Remuneration

AFMA responds to the consultation on the BEAR variable remuneration.

Regulation APRA
30-Apr-2019

ASX 90 Day Bank Bill Futures Contract Changes Consultation

AFMA welcomes the ASX's consultation on changes to the 90 Day Bank Bill Futures Contracts as a positive step in evolving and growing the market.

Regulation ASX
26-Apr-2019

COGATI Implementation - Access and Charging

An AFMA submission to the AEMC on a consultation paper regarding COGATI implementation - Access and Charging. The introduction of dynamic regional pricing represents significant reform which has been presented as a solution without due consideration of costs and benefits of its implementation or of alternative solutions, and more detailed analysis of costs and benefits is desirable before major implementation decisions are made. It also introduces basis risk for generators who enter into hedging contracts based on the regional reference price, however may receive a different dynamic regional price.

Regulation AEMC
18-Apr-2019

Enforceability of financial services consumer industry codes

AFMA is making comment on the Consultation Paper entitled 'Enforceability of financial services industry codes'. This takes up recommendation 1.15 of the Banking, Superannuation and Financial Services Royal Commission.

Regulation The Treasury
16-Apr-2019

APRA Capability Review

AFMA welcomes the opportunity to provide comment to the APRA Capability Review.

Regulation The Treasury
28-Feb-2019

ASX Listing Rules Update Consultation

AFMA is making comment on the Consultation Paper entitled 'Simplifying, clarifying and enhancing the integrity and efficiency of the ASX listing rules'.

Regulation ASX
05-Feb-2019

APRA Discussion Paper: Increasing the loss-absorbing capacity of ADIs to support orderly resolution

AFMA welcomes the opportunity to make comment on APRA's proposals in relation to increasing the loss-absorbing capacity of ADIs to support orderly resolution.

Association APRA
31-Jan-2019

2019-20 Pre-Budget Submission

AFMA is pleased to provide a submission to Treasury to assist in the formulation of the Government's 2019-20 Federal Budget.

Taxation The Treasury
14-Jan-2019

Markets Disciplinary Panel Regulatory Guide Consultation (CP 306)

AFMA welcomes the opportunity to make comment on Consultation Paper 306 Markets Disciplinary Panel (CP 306).

Regulation ASIC