Submissions
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CFR Small and Medium-sized Banks Review
14 February 2025
AFIA provided a submission to CFR Review into Small and Medium-sized Banks which advocates for a financial system that supports diverse business models, encourages innovation, and ensures that regulation does not inadvertently entrench advantages for larger players at the expense of smaller banks and non-bank lenders.
RBA Review of Merchant Card Payment Costs and Surcharging
6 December 2024
AFIA responded to the Reserve Bank of Australia Review of Merchant Card Payment Costs and Surcharging. Our comments build upon our previous submissions to Treasury on reforms to the payments system.
AI Mandatory Guardrails
AFIA submitted its response to Industry on 4 October 2024 regarding mandatory guardrails for AI in high-risk settings: proposals paper. The proposal aims to address AI risks across the economy. The Guardrails intend to apply to high-risk settings, with credit applications specifically highlighted in the consultation.
Proposed Updates to Regulatory Guide 274 – Product design and distribution obligations (RG 274)
On 28 August 2024, AFIA responded to the proposed updates by the Australian Securities and Investments Commission to Regulatory Guide 274 – Product design and distribution obligations (RG 274).
Extending the Small Business Responsible Lending Obligations Exemption
On 19 August 2024, AFIA responded to Treasury’s proposed extension of the small business responsible lending obligations exemption. Our response highlights AFIA’s support for the exemption being extended, noting the critical importance of small businesses having access to easily available and appropriately offered credit.
Sustainable Finance Strategy
On 1 December 2023, AFIA responded to the Government’s Sustainable Finance Strategy consultation paper.
Draft Consumer Data Right Rules for Non Bank Lending
On 6 October 2023, AFIA made a submission on the draft amendments to the Competition and Consumer (Consumer Data Right) Rules 2020.
Decision Proposal 316 - Non-Bank Lending sector alignment
On 25 August 2023, AFIA responded to Decision Proposal 316, the Non-Bank Lending sector alignment for the Consumer Data Right (CDR) ecosystem.
Second consultation on climate related disclosures
On 21 July 2023, AFIA made a submission to Treasury’s second consultation paper on climate-related financial disclosure and the Australian Government’s commitment to a sustainable finance strategy.
Reforms to the Payment Systems (Regulation) Act 1998 – Consultation Paper
On 7 July 2023, AFIA made a submission to the Government’s proposed updates to the Payment Systems (Regulation) Act 1998 (‘the PSRA’).
Proposed Reforms to Australia's Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) Regime
On 16 June 2023, AFIA made a submission to the Attorney-General’s Department on proposed reforms to Australia’s Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) regime.
AFCA Consultation on its Rules and Operational Guidelines
On 4 May 2023, AFIA made a submission to the Australian Financial Complaints Authority (AFCA) Rules and Operational Guidelines – Proposed amendments consultation.
Proposed Changes to Thin Capitalisation Rules
On 13 April 2023, AFIA made a submission to Treasury’s consultation on proposed changes to the thin captalisation rules for financial entities.
Privacy Act Review
AFIA lodged our submission to the Attorney-General’s Department on their consultation regarding the Privacy Act Review. The review’s final report proposes 116 potential changes to the Privacy Act 1988 (Cth).
AFIA Submission to Treasury on Electronic Precontractual Disclosures
On 16 March 2023, AFIA made a submission to this Treasury consultation. The consultation included proposed amendments to the National Consumer Credit Protection Act 2009 (Cth)(the Credit Act) and regulations.
NZ Regulation of BNPL
On 10 March 2023, AFIA made a submission on Buy Now, Pater Later (BNPL) regulation in New Zealand to the Ministry of Business, Innovation and Employment (MBIE).
Designing Australia's Sustainable Finance Taxonomy
On 17 February 2023, AFIA made a submission to the framing paper on ‘Designing Australia’s Sustainable Finance Taxonomy’.
Climate-related financial disclosure – consultation
On 17 February 2023, AFIA made a submission to Treasury’s consultation paper on climate-related financial disclosure.
AFIA Submission to Treasury - Regulating BNPL in Australia
AFIA today released its submission to Treasury’s Options Paper: Regulating Buy Now, Pay Later in Australia.
Strategic Plan for the Payments System: Consultation Paper
On 7 February 2023, AFIA made our submission to Treasury’s consultation on the Strategic Plan for the Payments System.