| 25-Jul-2025 |
AFMA made nine recommendations to proposals to boost national productivity, dynamism, and growth in the financial services sector.
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Regulation |
Treasury |
| 17-Jul-2025 |
AFMA's submission recommended that the registration process and maintenance be as efficient as possible and that a coherent timetable for implementing the scheme would be beneficial to the market. AFMA expressed the view that a high functioning certificate register is key to the success of the scheme.
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Regulation |
DCCEEW |
| 14-Jul-2025 |
AFMA's submission proposed that FERM should be designed to work with the recommendations of the NEM Market Settings Review, noting that it was unclear why FERM needs to support long-duration firm capacity after the commencement of the NEM Market Settings Review’s recommendations. In addition, AFMA believes the proposed Reliability Obligation is unnecessary. AFMA recommended that units that do not receive payments under FERM should only be required to advise if they intend to close during the commitment period and should not be required to give a capacity commitment.
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Regulation |
South Australian Government |
| 11-Jul-2025 |
AFMA's submission welcomed the recent development by the state and federal issuers of common bond turnover reporting standards, while seeking clarity on technical matters.
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Regulation |
AOFM |
| 10-Jul-2025 |
AFMA's submission did not support the rule change and views that the proposed option will increase prices for consumers. Further, AFMA noted that the rule change process has left inadequate time to properly consider the issues identified during consultation.
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Regulation |
AEMC |
| 30-Jun-2025 |
AFMA's submission provided feedback to the consultation questions and also suggested consideration of extension of Price Limits (AOT/ETR) to IR Futures.
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Regulation |
ASX |
| 27-Jun-2025 |
AFMA's submission supports a set of Rules that gives effect to the FATF recommendations, respects the primacy of comparable FATF-compliant jurisdictions and facilitates compliance in a risk-based manner. The submission sets out a number of potential enhancements to the current draft Rules.
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Regulation |
AUSTRAC |
| 27-Jun-2025 |
AFMA's submission broadly supported the ISSB's amendments and encouraged permitting early adoption. AFMA sought clarity regarding treatment of REPOs, Reverse REPOs and Options.
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Regulation |
International Sustainability Standards Board |
| 13-Jun-2025 |
AFMA's submission proposed that to the extent that AFCA amends its Rules to allow jurisdiction to investigate scam-related complaints against banks where the complainant is not a customer, the scope of “bank” for this purpose should only be those banks authorised by APRA to provide services to retail customers.
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Regulation |
AFCA |
| 11-Jun-2025 |
AFMA's submission welcomed Cboe proceeding with its plans for listings and the increased competition it will bring. AFMA encouraged Cboe to ensure regulatory consistency between its different listing entities and measures to support the success of the listings.
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Regulation |
Cboe |
| 11-Jun-2025 |
AFMA's submission highlighted that we were not aware of any similar comparability assessment nor cross-border relief from NFA compliance rules to non-US swap dealers for activities that are outside the scope US swap dealing with US Persons and that the absence of any relief impacts Australian non-US Swap dealers who (for prudential reasons) include swap dealer activity within the same legal entity as the retail, business, institutional, broker-dealer and treasury activities.
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Regulation |
National Futures Assocation |
| 11-Jun-2025 |
AFMA agreed that the ESS and PDRS have functioned efficiently and that we view the ESS surplus and decreasing price signals a successful market.
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Regulation |
NSW Government |
| 11-Jun-2025 |
AFMA expressed that the NEM Wholesale Market Settings Review, combined with the Safeguard Mechanism, should provide policy certainty to manage the energy market transition and that clearer , more consistent policy to support the role of gas through the transition is required.
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Regulation |
Productivity Commission |
| 11-Jun-2025 |
AFMA's submission to the Productivity Commission highlights tax frictions that hamper investment and generate compliance costs. AFMA's submission suggested that financial sector participants are facing increasing regulatory burden and included areas for reform.
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Regulation |
Productivity Commission |
| 06-Jun-2025 |
AFMA re-stated its support for Government to adopt a more pro-innovation approach as is the case in the UK and US rather than one more aligned with the restrictive EU and Canadian regulatory regimes. While supportive of the proposed CDR scheme reset, AFMA's submission stated it does not go sufficiently far to address these issue.
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Regulation |
Productivity Commission |
| 06-Jun-2025 |
While supportive of APRA's initiatives to strengthen the prudential governance framework, AFMA made eight recommendations that to safeguard Boards' capacity to support and drive growth and innovation within their organisations.
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Regulation |
APRA |
| 19-May-2025 |
AFMA's submission highlighted that we do not support the reporting of firm-level data for Reportable Situations reporting, particularly for wholesale clients.
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Regulation |
ASIC |
| 16-May-2025 |
AFMA's submission seeks additional clear exclusions in the Determination for transactions used in wholesale financial markets.
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Regulation |
Treasury |
| 15-May-2025 |
AFMA was supportive of making this rule change and believes that the cash cap should be increased to more than $50 million. AFMA's submission recommended that prudential supervision requirements for credit support providers should remain aligned with broader financial service law.
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Regulation |
AEMC |
| 09-May-2025 |
AFMA writes to APRA seeking consideration of aligning two Required Stable Funding (RSF) factors to increase efficiencies in financial markets and reduce a competitive disadvantage faced by Australian banks.
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Regulation |
APRA (Ms Santosaputri) |
| 08-May-2025 |
AFMA's submission was supportive of the the introduction of a gas PASA and AFMA submitted that the PASA should be published frequently enough to meet the needs of the market.
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Regulation |
AEMC |
| 07-May-2025 |
AFMA submitted that given the specific nature of the questions asked were best answered by individual firms, and this is appropriate to give ASX a view of the technical preferences of its participants.
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Regulation |
ASX |
| 07-May-2025 |
AFMA's submission highlighted the consensus view of our membership is that there is a mix of cyclical and structural drivers in the growth in private capital markets. AFMA sees substantial scope for increasing the attractiveness of public markets through adjustments to laws, regulations and regulatory stances by ASIC, many of which could be readily implemented. AFMA explained that private markets fulfil a different function to public markets, and we do not believe that the two necessarily need to align and that caution needs to be exercised in imposing additional law and regulation on private markets.
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Regulation |
ASIC |
| 02-May-2025 |
AFMA's submission expressed that the current high-volume methodologies should not be retired until appropriate replacement methodologies are in place and that proposals that risk supply, market liquidity and consumer prices should be reconsidered.
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Regulation |
NSW DCCEEW |
| 17-Apr-2025 |
AFMA supports the proposed introduction of a gas reliability standard and formalised reviews of gas market settings; however, AFMA's submission expressed that the standard should be set by an independent panel rather than the AEMC.
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Regulation |
AEMC |
| 27-Mar-2025 |
AFMA urged DCCEEW to provide implementation timeframes for all products. The submission also expressed that development of the register should be prioritised and that consultation on storage, hybrid systems and below baseline should begin.
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Regulation |
DCCEEW |
| 10-Mar-2025 |
AFMA's submission welcomed the review but stated that certifying new, durable and scaleable methodologies should be of highest priority. Likewise, additional measurers should be taken to ensure that market participants are fit and proper.
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Regulation |
Victorian Government |
| 28-Feb-2025 |
AFMA's submission highlighted that the review should look to restore the decisive role of the market in NEM investment and that sucessfully managing the retirement of coal units is critical to allowing the energy market to navigate the energy transition.
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Regulation |
NEM Settings Review Panel |
| 21-Feb-2025 |
AFMA's submssion did not support the proposalson the basis that they have not been adequately developed with the aid of industry consultation and are not acceptable in their current form.
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Regulation |
Treasury |
| 20-Feb-2025 |
AFMA provided responses to IOSCO's consultation questions. While AFMA was in agreement on some elements, AFMA made a series of drafting recommendations, fundamentally not agreeing with the definition of pre-hedging.
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Regulation |
IOSCO |
| 07-Feb-2025 |
AFMA’s submission highlighted challenges and opportunities regarding the evolution of Australia as a financial services centre and both the role and importance of foreign banks in Australia.
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Regulation |
CFR and ACCC |
| 07-Feb-2025 |
AFMA's submission supported the proposed market-based certificate scheme and that the costs of the scheme should be borne by all users.
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Regulation |
DEECA |
| 31-Jan-2025 |
AFMA's submission set out that the concerns the PEMM Act was intended to address are better dealt with by other regulation and that the provisions have been ineffective and should be repealed. AFMA recommended that theACCC’s Electricity Pricing Inquiry should conclude as scheduled in 2025.
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Regulation |
Department of Climate Change, Energy, the Environment and Water |
| 31-Jan-2025 |
AFMA's submission highlighted that foreign banks are a crucial element of the Australian economy that need to be more appropriately considered in policy formation. In addition, the submission noted that Australia’s financial centre competitiveness has been in continuous decline since the Royal Commission/pandemic and AFMA belives Australia should prioritise initiatives to boost Australia’s attractiveness as a place to do business.
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Regulation |
Treasury |
| 30-Jan-2025 |
AFMA’s submission supported the AEMC’s decision to adopt AEMO’s approach to allocating positive residues. However, AFMA remains unconvinced that there is a need for a broader review of SRA at this time.
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Regulation |
AEMC |
| 16-Jan-2025 |
AFMA's submission stated that there is currently inadequate VEEC supply to meet demand and that targets should be aligned with realistic expectations of the volume of VEECs expected to be created.
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Regulation |
Victorian Department of Energy, Environment, and Climate Action |
| 16-Jan-2025 |
AFMA's submission stated that the changes that are proposed are too complex in their implications and that the proposed amendments to the current regime extend beyond FATF recommendations relating to beneficial ownership and beyond listed company disclosure requirements in other jurisdictions.
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Regulation |
Treasury |
| 09-Jan-2025 |
AFMA submitted that the ADIs that should be subject to the Mandatory Code are only those that are authorised by APRA to provide services to retail customers, as opposed to all ADIs. The Impact Statement that accompanies the Explanatory Memorandum should not undermine the Minister’s authority to designate regulated sectors/services by assuming that foreign bank branches are within regulatory scope.
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Regulation |
Senate Standing Committees on Economics |