Category: Banking Culture

AMP Financial Planning Ceases MDA Services

AMP Financial Planning Pty Ltd (AMPFP) ceased providing managed discretionary account (MDA) services on 10 December 2019 following the imposition of tailored licence conditions by ASIC.

In March 2019, following a surveillance of AMPFP’s MDA services and advice business, ASIC granted AMPFP’s application to vary its Australian financial services (AFS) licence to provide MDA services, subject to some tailored licence conditions (19-078MR). The tailored conditions formalised commitments made by AMPFP, in response to ASIC’s concerns, to improve monitoring and supervision of its discretionary investment services and related financial advice.

Under the tailored licence conditions, a Senior Executive of AMPFP was required to provide an acceptable attestation to ASIC by 30 September 2019 confirming that AMPFP had complied with and was complying with the tailored conditions. This was to ensure that all of the required improvements to monitoring and supervision practices had been implemented and were operating effectively.

AMPFP did not provide ASIC with an acceptable attestation in relation to its provision of MDA services. The attestation provided by AMPFP had exceptions and ASIC informed AMPFP that the attestation was not acceptable to it, and AMPFP ceased providing MDA services in accordance with its licence conditions.  

Background

MDAs create particular risks for retail clients because when a client enters into a contract with an MDA provider, they give the provider authority to make investment decisions on their behalf on an ongoing basis without seeking the client’s prior approval.

The risks increase if the person recommending the MDA service and making or influencing the investment decisions are the same because the clients may not be receiving impartial advice about the decision to enter into or remain in the MDA service. ASIC expects AFS licensees to consider the risks involved with the financial advice and investment activities of their representatives in their monitoring and supervision practices. 

US Agencies Find “Shortcomings” For Several Large Financial Firms

The Federal Reserve Board and Federal Deposit Insurance Corporation announced Tuesday that they did not find any “deficiencies,” which are weaknesses that could result in additional prudential requirements if not corrected, in the resolution plans of the largest and most complex domestic banks. However, plans from six of the eight banks had “shortcomings,” which are weaknesses that raise questions about the feasibility of a firm’s plan, but are not as severe as a deficiency. Plans to address the shortcomings are due to the agencies by March 31, 2020.

Resolution plans, commonly known as living wills, describe a bank’s strategy for rapid and orderly resolution under bankruptcy in the event of material financial distress or failure.

In the plans of Bank of America, Bank of New York Mellon, Citigroup, Morgan Stanley, State Street, and Wells Fargo, the agencies found shortcomings related to the ability of the firms to reliably produce, in stressed conditions, data needed to execute their resolution strategy. Examples include measures of capital and liquidity at relevant subsidiaries. The agencies did not find shortcomings in the plans from Goldman Sachs and J.P. Morgan Chase.

The firms will receive feedback letters, which will be publicly available on the Board’s website. For the six firms whose plans have shortcomings, the letter details the specific weaknesses and the actions required. Overall, the letters note that each firm made significant progress in enhancing its resolvability and developing resolution-related capabilities but all firms will need to continue to make progress in certain areas.

To that end, the letters confirm the agencies expect to focus on testing the resolution capabilities of the firms when reviewing their next plans. Resolving a large bank would be challenging and unprecedented, and the agencies expect the firms to remain vigilant as markets change and as firms’ activities, structures, and risk profiles change.

The agencies also announced on Tuesday that Bank of America, Goldman Sachs, Morgan Stanley, and Wells Fargo had successfully addressed prior shortcomings identified by the agencies in their December 2017 resolution plan review.

ASIC Takes Court Action Against NAB

ASIC has commenced civil penalty proceedings in the Federal Court against National Australia Bank Limited (NAB) and seeks findings of several thousand contraventions of the ASIC Act and the Corporations Act. 

ASIC alleges that from December 2013 to February 2019, NAB:

  • engaged in Fees for No Service Conduct by failing to provide ongoing financial planning services to a large number of customers while charging fees to those customers;
  • failed to issue, or issued defective, fee disclosure statements (FDSs). ASIC alleges that the defective FDSs contained false or misleading representations in that they did not accurately describe the fees the customer paid and/or the services the customer actually received. The provision of the defective or out-of-time FDSs terminated the ongoing fee arrangements between NAB and its customers and it is ASIC’s case that consequently NAB was not lawfully entitled to continue to charge the fees;
  • failed to establish and maintain compliance systems and processes to detect and prevent these failures; and
  • contravened its overarching obligations as an Australian Financial Services licence holder to act efficiently, honestly and fairly.

It is also ASIC’s case that NAB engaged in unconscionable conduct from at least May 2018 by continuing to charge ongoing service fees to certain customers when it knew that it had not delivered the services and had issued defective FDSs or at least knew that there was a real risk that it had engaged in this conduct. However, NAB did not stop charging fees to its customers until 4 February 2019.

ASIC is seeking declarations, pecuniary penalties and compliance orders from the Federal Court to prevent similar contraventions occurring in the future.

‘Fees for No Service misconduct has been widespread and is subject to ongoing ASIC regulatory responses including investigations and enforcement actions. This widespread misconduct was examined in some detail by the Financial Services Royal Commission. ASIC views these instances of misconduct as systematic failures, unfair to customers including those that are more vulnerable. 

‘When the Fees for No Service misconduct is coupled with Fees Disclosure Statements inadequacies or failings, customers are potentially placed in a more disadvantageous position. The customer may not therefore have been provided with the opportunity to know whether they have received the services for which they have paid or the amount of fees charged to them’ said ASIC Deputy Chair Daniel Crennan QC.

The maximum civil penalty for contraventions alleged against NAB are:

  • $250,000 per contravention for breaches of s962P (charging ongoing fees after the termination of an ongoing fee arrangement) and s962S (failing to provide a timely FDS);
  • $1.7 to $2.1 million maximum penalty (depending on the time period) per contravention for breaches of s12CB (unconscionable conduct) and s12DB (false or misleading representations).

NAB received more than $650 million in ongoing service fees from 2009 to 2018. NAB has stated that it has provisioned more than $2 billion for Fee for No Service remediation across all of its advice licensees.

Background

Fees for No Service conduct and remediation of that conduct by NAB and other licensees was examined as part of the Financial Services Royal Commission. ASIC has been monitoring NAB’s (and other licensees’) remediation of its fees for no service failures with the last update on its progress provided on 11 March 2019 (19-051MR).

On 28 November 2019, ASIC released Report 636 – compliance with the fee disclosure statement and renewal notice obligations (19-325MR).

As noted by Report 636, FDSs are intended to help customers understand what services they have paid for, what services they have received and how much those services cost, and to enable them to make more informed decisions about whether their ongoing fee arrangements with their adviser should continue. Not issuing or issuing late or defective FDSs deprive customers of an opportunity to make those important decisions. 

ASIC’s action against NAB falls within ASIC’s Wealth Management Major Financial Institutions Portfolio. The Portfolio focuses on the financial services conduct of Australia’s largest financial institutions (NAB, Westpac, CBA, ANZ, Macquarie and AMP) with respect to credit and retail lending, financial advice, fees for no service, superannuation trustees, insurance, unfair contract terms and other licensee obligations, and other conduct arising from the Financial Services Royal

APRA Launches Westpac Investigation

The Australian Prudential Regulation Authority (APRA) has today formally commenced an investigation into possible breaches of the Banking Act 1959 by Westpac Banking Corporation (Westpac).

APRA will focus on the conduct that led to the matters alleged last month by AUSTRAC, as well as the bank’s actions to rectify and remediate the issues after they were identified. The investigation will examine whether Westpac, its directors and/or its senior managers breached the Banking Act – including the Banking Executive Accountability Regime (BEAR) – or contravened APRA’s prudential standards.

Given the magnitude and nature of the issues alleged by AUSTRAC, APRA is aiming to ensure that fundamental deficiencies in Westpac’s risk management framework are identified and addressed and that Westpac and those responsible are held accountable as appropriate.

In addition, APRA will:

  • impose an immediate increase in Westpac’s capital requirements of $500 million, to reflect the heightened operational risk profile of the bank. This brings the total operational risk capital add-ons that Westpac is required to hold to $1 billion, following the increase announced by APRA in July 2019; and
  • initiate an extensive review program focused on Westpac’s risk governance. The review program will include risk management, accountability, remuneration and culture. An element of the review will be an examination of the steps Westpac has been taking to strengthen risk governance in recent years, including through its self-assessment.

APRA Deputy Chair Mr John Lonsdale said: “AUSTRAC’s statement of claim in relation to Westpac contains serious allegations that question the prudential standing of Australia’s second largest bank.

“While Westpac is financially sound, there are potentially substantial gaps in risk governance that need to be closed.

“Given the nature of the matters raised by AUSTRAC, the number of alleged breaches and the period of time over which they occurred, this will necessarily be an extensive and potentially lengthy investigation.”

The investigation affords APRA the opportunity to exercise legal powers that have been expanded and strengthened since 2017’s CBA Prudential Inquiry, including enhanced investigative powers and the implementation of the BEAR in 2018.

APRA will conduct its investigation simultaneously with an investigation by the Australian Securities and Investments Commission (ASIC), as well as AUSTRAC’s legal proceedings, with each agency cooperating where appropriate.

The scope of APRA’s investigation is below.


Attachment – Scope of APRA’s investigation into Westpac

The prudential matters that are the subject of APRA’s investigation are:  

Whether Westpac, its directors, and/or its senior managers have contravened the Banking Act 1959 and the prudential standards by engaging in, and in the way they responded to, the conduct set out in and otherwise related to the AUSTRAC proceedings.  

In considering possible contraventions of the Act and the prudential standards, the investigation will examine whether:  

(a) Westpac’s governance, control and risk management framework was adequate; and appropriately implemented;  

(b) Westpac’s accountability and remuneration arrangements were adequate, and appropriately implemented to effectively manage non-financial risks;  

(c) there has been a failure to comply with accountability obligations under the Banking Executive Accountability Regime;  

(d) there has been a failure to comply with the requirements of the prudential standards including Prudential Standard CPS 510: Governance, Prudential Standard CPS 520: Fit and Proper, and Prudential Standard CPS 220: Risk Management; and

(e) there was a failure to promptly notify APRA of any significant breaches and/or a breach of accountability obligations.

Has Deutsche Bank’s Tide Turned?

On 10 December, Deutsche Bank AG hosted an investor day following the announcement this summer of its more radical shift in strategy. Via Moody’s.

We see the bank as being on track to achieving the majority of the plan’s targets, in particular with regard to the proposed de-risking, downsizing and cost-cutting measures, while achievement of the revenue growth targets may prove more challenging. Continued fast and steady progress in achieving the new goals and repositioning DB’s business model will be important to maintaining its current credit strength, which we believe will continue to be supported by its clean balance sheet and solid capital and liquidity metrics during execution.

Within the bank’s capital release unit (CRU), its key wind-down unit, the bank expects risk-weighted assets (RWAs) to decline toward €52 billion by the end of 2019, down 28% year over year, while it expects leverage exposures to fall to €120 billion, a decline of 57% year over year. This includes the effect of DB’s transaction agreement with BNP Paribas on DB’s global prime finance and electronic equities business, supporting further swift de-risking and downsizing of the CRU, as well as help financing the group’s restructuring program out of its own financial resources. DB expects adjusted costs to be €21.5 billion in 2019, and reiterated its target of €19.5 billion of adjusted costs in 2020 and €17 billion in2021.

Notwithstanding continued strong credit-positive cost control, management also guided for lower revenue growth, largely owing to lower interest rates negatively affecting its private bank franchise. DB now expects group revenue to be around €24.5 billion by 2022, a slight reduction from the earlier €25 billion target. This includes a cumulative negative revenue effect of €1.2 billion during the restructuring period. However, DB has already initiated measures aimed at offsetting approximately two-thirds of this revenue strain. Sustained execution success will therefore rely on DB’s ability to rebuild and stabilize core bank revenue against the backdrop of the increasingly challenging macroeconomic environment.

Despite the meaningful restructuring-related charges to date, DB maintained its Common Equity Tier 1 (CET1) ratio at 13.4% as of 30 September 2019, a solid buffer above the recently lowered European Central Bank CET1 capital ratio requirement of 11.59%. In addition, DB’s €243 billion liquidity reserve is well in excess of the requirements stipulated by the liquidity coverage ratio, which was 139% as of 30 September 2019 (its net buffer was €59 billion). DB expects its corporate bank unit to report compound revenue growth of 3% during the 2018-22 restructuring period, unchanged from the July announcement. DB aims to build on its strong global transaction banking, cash management and securities service franchises,as well as grow lending to German corporate customers.

DB expects costs to remain virtually flat as it retains client-facing staff and continues to invest in its franchise. Revenue growth will be supported by focusing on the aforementioned focus areas, as well as passing on negative interest rates to partly compensate for challenges in the euro area.

The investment bank unit aims to achieve 2% compound revenue growth, with an increase expected during the 2019-22 period. DB cited stronger-than-anticipated client retention and a rise in top 100 institutional client revenue as supporting its goals over the next few years. The investment bank unit’s profitability should further benefit from the announced cost-cutting measures over time, of which parts will have to be reinvested in technology and infrastructure to maintain leading positions in credit, foreign exchange, fixed income and currencies in Asia-Pacific and Europe, Middle East and Africa. The private bank will suffer most from the even lower interest rate environment. The bank now expects compound revenue growth to be flat over the 2018-22 period, a reduction from the 2% target set out in July. Private banking will remain key to extracting synergies from the integration of the DB franchise with the former Postbank, converting low-margin deposits into fee-producing investment products through collaboration with asset and wealth management, as well as the corporate bank.

The bank expects its asset management unit’s revenue to report a compound annual growth rate of 1% during the period. The reduced target takes into account lower equity market forecasts and a continued strain on margins in the asset management industry. The unit aims to extract a further €150 million of gross cost synergies by 2022, moving its cost-to-income ratio to below 70% (the bank’s asset management unit target is around 65%). Assets under management increased by 9% to €754 billion, driven by positive market performance and another quarter of positive net new money flows. The CRU has been able to downsize exposures faster than anticipated. Quickly reducing the CRU’s revenue and profitability drag to achieve fast and steady progress in reaching the new goals and repositioning DB’s business model will be important to maintaining its current credit strength, as well as safeguarding its capital adequacy metrics.

Adam And I Chat…

I was interviewed by Adam Stokes who runs his own YT channel, mainly covering Crypto. This is my version of the discussion.

The show covered a wide range of issues, from Crypto, Central Banks, Cash Bans and Negative Rates through to politics and democracy.

Adam’s version: https://www.youtube.com/watch?v=vWzhuqM_aoU

Check out his channel: https://www.youtube.com/user/adamstokes224

Bank Weights Overload Australians

With Westpac shares trading at a seven-year low following the alleged breach of anti-money laundering laws and three of the four big banks recently cutting dividends or franking credits, investors should consider cutting their exposure to the big banks to avoid the erosion of their wealth and income. Via InvestorDaily.

Early in November, even before AUSTRAC claimed Westpac did not comply with anti-money laundering laws 23 million times, the company shocked investors when it announced that it was cutting dividends for the first time since 2008 after its full-year 2019 cash profit fell 15 per cent to $6.85 billion. The bank slashed its final dividend to 80 cents from 94 cents a share. ANZ too recently cut the level of franking of its dividends to 70 per cent from 100 per cent while NAB cut its final and interim dividends to 83 cents a share from 99 cents for 2019.  

The big banks will most probably find it difficult to maintain existing payouts to shareholders given the economic climate of historically low interest rates and lacklustre economic growth. The graph below highlights that the big banks are much less profitable now than they were 10 years ago. The return on equity to shareholders has fallen from around 20 per cent in 2008 to close to 10 per cent at current levels. This is sounding alarm bells for investors looking for reliable income and capital growth. As the banks’ profitability falls, the risk is that shareholders will see more dividend cuts and even more capital losses on top of those they have already sustained. 

The chart below highlights that the big banks’ net interest margins (NIM) have also dropped to their lowest level of around 2 per cent, which is putting downward pressure on their profits. Falling NIMs and a rising regulatory spend in the aftermath of the Hayne royal commission are combining to reduce banks’ profits.

The outlook for profitability is not good. Low interest rates are likely to persist for a long time in Australia and abroad. High levels of household debt in Australia will inevitably hamper future growth in earnings from mortgages and households save more. Household debt sits at around 190 per cent of household income, higher than in most other countries. While most households are comfortably making their debt repayments now, any shocks to the economy such as significant rise in unemployment could push some households over the edge.

Added to this are remediation costs for the banks associated with poor customer outcomes and regulatory non-compliance, which, according to Reserve Bank figures, have amounted to $7.5 billion across the financial sector over the past two years and are still rising. That figure does not count Westpac’s likely escalation in remediation costs, law suits and potentially record-breaking fine following AUSTRAC’S prosecution of its alleged 23 million breaches of anti-money laundering laws. APRA has also imposed additional capital requirements on the major banks to account for poor risk management practices. All of these are weighing on banks’ ability to make money.

This is sobering news for shareholders. Dividend cuts and falling share prices and profits are alarming outcomes for the many Australian investors whose portfolios have significant exposure to the big four, which represent around one-quarter of the S&P/ASX 200. In other words, if you hold a blue-chip portfolio or are invested in an active or passively managed Australian equity fund that tracks or is benchmarked to the S&P/ASX 200, $1 out of every $4 is likely to be invested in banks and therefore vulnerable to the risks they face. In the last month alone (to 4 December), Westpac shares are down 10 per cent and over five years, they have fallen 25 per cent. NAB shares are down 16 per cent and ANZ 23 per cent. Commonwealth Bank has lost a relatively modest 0.6 per cent.  But these are dire financial outcomes for shareholders.

APRA’s MySuper Heatmap Is A Nightmare

From the excellent James Mitchell, at The Adviser. If the prudential regulator was hoping to provide clarity on MySuper products it has failed miserably.

Call me ignorant, but when APRA announced the launch of its MySuper heatmap, I didn’t envision downloading an Excel spreadsheet and navigating multiple tabs in order to decipher what the hell I was looking at. If this monstrosity is intended to be fit for public consumption then the average Australian better have a financial adviser by their side, if for no other reason than to decode the thing. 

Fortunately, the team who put the spreadsheet together included a “user guide” on tab 4 (see below). Crikey!

There is also a colour legend and a glossary of definitions for terms such as “strategic asset allocation” and “net investment return”. 

My fear is that the average Australian super member looking to compare funds will struggle to comprehend what APRA’s heatmap actually means. Particularly when you consider what the financial literacy of an average Australian actually looks like. 

Back in August, Compare the Market and Deloitte Access Economics released the second edition of The Financial Consciousness Index, which measures the extent to which Aussies are conscious or aware of their ability to affect and change their own financial outcomes, encompassing their willingness to act, and the extent to which they are able to participate in financial matters.

Australians scored 48 per cent on average on the index, which means they are just into the “conscious” band and out of the “it’s a blur” band.

Meanwhile, ASIC’s 2018 Financial Capability initiative noted that two in three Australians don’t understand the investment concept of diversification and only 35 per cent know what their super balance is. 

With this in mind, it’s difficult to fathom how APRA’s overly complex Excel spreadsheet is going to translate, let alone be used as a guide, to everyday Australians. 

FSC CEO Sally Loane warned against the misuse of the thing and said it should not be used to rank superannuation products. 

“It is really important to understand that the heatmaps are a point-in-time analysis, which is a useful tool for APRA in its supervision activities, but it doesn’t tell the whole story when it comes to members’ retirement outcomes,” Ms Loane said. 

“Particularly for life cycle products, which adjust investment strategies over a person’s lifetime, the headline numbers in the heatmap don’t reflect the actual experience of a member in that fund, and could be misleading if viewed in isolation.”

The FSC noted that the heatmap may tell you that other funds have had higher returns over five years, but if you’re close to retirement you might be far more concerned with how your fund is managing the risks of a market downturn to safeguard your retirement savings.

Some of the heatmap’s other failings are that it doesn’t tell you how your super has performed over your lifetime, it can’t tell you whether your fund invests in accordance with your ethical and philosophical beliefs, and it doesn’t tell you what additional services they offer to help you manage your savings. 

“If you have concerns about whether your super fund is right for you, talk to your fund or speak to a financial adviser,” Ms Loane said. 

Ms Loane said that while the FSC hoped APRA would continue to refine its MySuper heatmap methodology, the proposal to extend the exercise to choice products was highly problematic.

“The broad variety of choice products in the market, the complexity and bespoke nature of platforms and wraps where individuals choose their investment strategies, and the lack of direct comparable data, [make] it extremely difficult to translate heatmapping beyond MySuper and we urge APRA to not only be cautious in proceeding with this exercise but to engage deeply with industry,” she said.

RBNZ Imposes Higher Capital

The Reserve Bank of New Zealand today released its final decisions following its comprehensive review of its capital framework for banks, known as the Capital Review. The trajectory will be over a longer period, with more flexibility, but the banks will still need to hold more capital.

Governor Adrian Orr said the decisions to increase capital requirements are about making the banking system safer for all New Zealanders, and will ensure bank owners have a meaningful stake in their businesses. The changes will be implemented over seven years, giving plenty of time for banks to manage a smooth transition and minimise any adjustment costs.

“Our decisions are not just about dollars and cents. More capital in the banking system better enables banks to weather economic volatility and maintain good, long-term, customer outcomes,” Mr Orr says.

“More capital also reduces the likelihood of a bank failure. Banking crises cause not only harmful economic costs but also distressful social issues, such as the general decline in mental and physical health brought about by higher rates of unemployment. These effects are felt for generations,” Mr Orr says.

The key decisions, which start to take effect from 1 July 2020, include banks’ total capital increasing from a minimum of 10.5% now, to 18% for the four large banks and 16% for the remaining smaller banks. The average level of capital currently held by banks is 14.1%.

Relative to the Reserve Bank’s initial proposals, the final decisions also include:

  • More flexibility for banks on the use of specific capital instruments;
  • A more cost-effective mix of funding options for banks;
  • A lesser increase in capital for the smaller banks consistent with their more limited impact on society should they fail;
  • A more level capital regime for all banks – with the four large banks having to measure the risks of their exposures (lending) more conservatively, more in line with the smaller banks; and
  • More transparency in capital reporting.

The adjustments to the original proposals reflect our analysis and industry feedback over the past two years. All of these changes will be phased in over a seven-year period, rather than over five years as originally proposed, in order to reduce the economic impacts of these changes.

Deputy Governor and General Manager of Financial Stability Geoff Bascand says the decisions were shaped by valuable public input and insight received through an unprecedented number of submissions as well as public focus groups. Three international experts also provided supportive perspectives on the proposals.

“We’ve listened to feedback and reviewed all the data, and are confident the decisions are the right ones for New Zealand,” Mr Bascand says.

“We have amended our original proposals in a number of ways so we achieve a high level of resilience at lower potential cost, with a smoother transition path for all participants. Our analysis shows that the benefits of these changes will greatly outweigh any potential costs.”

“Following the Global Financial Crisis, many regulators around the world have been taking steps to improve the safety of their banking systems. We’re confident we have the calibrations right for New Zealand conditions. These changes will be subject to monitoring, with the Reserve Bank reporting publicly on implementation during the transition period,” Mr Bascand says.

APRA proposes major uplift in transparency around banking data

The Australian Prudential Regulation Authority (APRA) has proposed substantially increasing the volume and breadth of data it makes publicly available on authorised deposit-taking institutions (ADIs), including banks, credit unions and building societies.

The move towards greater transparency and scrutiny of the banking sector is aimed at increasing accountability, supporting competition and lifting overall industry standards.

In a letter to industry today, APRA outlined plans to determine that all data collected for its quarterly ADI publications should be considered non-confidential, allowing it to be published. APRA currently publishes less than 1 per cent of the ADI data it collects due to legal restrictions contained within the Australian Prudential Regulation Authority Act 1998 (APRA Act). This change would allow APRA to significantly increase this figure.

From 2020, APRA proposes publishing:

  • entity-level ADI data related to currently published industry-level quarterly data;
  • remaining historical data in these forms that individual ADIs are required to provide APRA, which will be published with a three-year lag; and
  • commentary received by APRA from individual ADIs explaining material revisions to, or large movements in, their data.

The proposal supports APRA’s strategic policy of increasing the transparency of data it collects, and aligns with Government open data policies.

APRA’s Executive Director for Cross-Industry Insights and Data, Sean Carmody, said: “APRA is committed to increasing transparency about the institutions and industries we regulate.

“Under these proposed changes, APRA intends to publish – for the first time – a range of information about individual ADIs, including their financial performance and property exposures.

“As with the recent inclusion of data from credit unions and building societies in our Monthly ADI Statistics publication, these changes are aimed at further strengthening the ADI sector by enhancing accountability and encouraging competition. They will also assist other regulatory agencies that rely on APRA data, as well as analysts, policymakers and others who use our publications.”

Under the APRA Act, APRA must consult ADIs and their representatives, including industry associations, before determining any new data to be non-confidential. A 12 week consultation is now underway and concludes on 28 February 2020. APRA is encouraging all interested parties to make submissions on issues including what, if any, data should remain confidential.

APRA intends to consult on forms not included in this consultation at a later date.

More details on the consultation, including the letter to industry, can be found at: https://www.apra.gov.au/confidentiality-of-data-used-adi-quarterly-publications-and-additional-historical-data