Submissions

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Date Resource Type Topic
13 Mar 2024 Submission to RBA consultation on new criteria for eligible self-securitisations

Letter to the RBA in response to the second and final consultation paper on the new legal criteria for eligible self-securitisations. 

Submission Regulatory and Prudential, Submission
02 Feb 2024 Supplementary submission to New Zealand Government Finance and Expenditure Committee on taxation

Taxation (Annual Rates for 2023-24, Multinational Tax, and Remedial Matters) Bill: Supplementary submission

Submission New Zealand, Submission, Taxation
11 Dec 2023 ASF Response to Consultation Paper - Statutory Review of the Personal Property Securities Act 2009

Submission to the Attorney General's Department...

Submission Submission
09 Oct 2023 Letter to Treasury on Consumer Data Right (CDR) in non-bank lending

Consumer Data Right (CDR) in non-bank lending – Consultation on Non-bank Lending Draft Rules – Australian Securitisation Forum response

Submission Regulatory and Prudential, Submission
01 Sep 2023 ASF submission to Revenue NSW on SECTION 8(1)(b)(ix) OF THE DUTIES ACT 1997

Submission raises ASF concerns about the potential scope of new section 8(1)(b)(ix) of the Duties Act 1997 (NSW) (“Duties Act”) where there is currently uncertainty about where stamp duty is payable in securitisation and covered bonds transactions.

Submission Submission, Taxation
22 Aug 2023 Submission to RBA consultation on new criteria for eligible self-securitisations.

The ASF with input from a working group comprised of a broad section of its members has prepared and submitted a letter to the RBA submission responding to the changes and the questions posed in the consultation on new criteria for eligible self-securitisations

Submission Regulatory and Prudential, Submission
21 Aug 2023 Submission to the Inquiry into the Treasury Laws Amendment Bill 2023

Submission to the Inquiry into the Treasury Laws Amendment (Making Multinationals Pay Their Fair Share-Integrity and Transparency) Bill 2023 (draft Bill)

Submission Submission, Taxation
21 Aug 2023 Submission to the Inquiry into the Treasury Laws Amendment Bill 2023

Submission to the Inquiry into the Treasury Laws Amendment (Making Multinationals Pay Their Fair Share-Integrity and Transparency) Bill 2023 (draft Bill)

Submission Submission, Taxation
13 Jul 2023 Submission to New Zealand Government Finance and Expenditure Committee on taxation

Submission: Taxation (Annual Rates for 2023-24, Multinational Tax, and Remedial Matters) Bill

 

External Resource New Zealand, Submission, Taxation
19 May 2023 Submission to RBNZ Liquidity Policy Review

Submission from the ASF New Zealand subcommittee ro RBNZ on its Liquidity Policy Review - Consultation paper #2 – Significant Policy Issues

Submission New Zealand, Regulatory and Prudential, Submission
18 Apr 2023 ASF Submission to Treasury on Thin Capitalisation Amendment Exposure Draft

Submission to the Australian Treasury on the thin capitalisation exposure draft....

Submission Submission, Taxation
10 Feb 2023 ASF Letter to Treasury re CDR rules and data standards

Consumer Data Right (CDR) in non-bank lending – Consultation on design of CDR rules and data standards – Australian Securitisation Forum responses to Design Paper dated December 2022

Submission Regulatory and Prudential, Submission
15 Dec 2022 Letter by industry associations to European Supervisory Authorities regarding Article 5(1)(e)

A letter addressed to the Joint Committee of the European Supervisory Authorities regarding Article 5(1)(e) of the Securitisation Regulation co-signed by the key participants in the European, American and Australian securitisation markets. The letter aims to draw attention to the de facto exclusion of EU institutional investors from investing in certain third-country securitisations due to the interpretation of the above article...

Submission Europe, Regulatory and Prudential, Submission
09 May 2022 ASF letter to Treasury: Consumer Data Right Expansion to Open Finance - Non Bank Sectoral Assessment

Letter in response to Treasury’s consultation paper dated 15 March 2022 on the Consumer Data Right Open Finance Sectoral Assessment - Non-bank lending (consultation paper).

Submission Regulatory and Prudential
21 Feb 2022 Public consultation on exposure draft Deposit Takers Bill (DTB) – ASF Submission

Public consultation on exposure draft Deposit Takers Bill (DTB) – ASF New Zealand subcommittee submission to the Reserve Bank of New Zealand.

Submission New Zealand
08 Feb 2022 ABSF Review Consultation - ASF response

Australian Business Securitisation Fund Review consultation – Australian Securitisation Forum Response to Treasury

Submission ABSF and SFSF
03 Nov 2021 ASF Submission to Select Committee on Tax Bill

Australian Securitisation Forum’s submission to the Finance and Expenditure Committee on the Taxation (Annual Rates for 2021-22, GST, and Remedial Matters) Bill (New Zealand).

Submission New Zealand
01 Oct 2021 EU targeted consultation on the functioning of the EU securitisation framework

ASF response to those parts of the “EU targeted consultation on the functioning of the EU securitisation framework” relevant to and impacting on ‘third country’ investment.  The response is aligned with the responses provided by both the Association for Financial Markets in Europe (AFME) and the US Structured Finance Association (SFA). View the consultation here
 

Submission Europe, Regulatory and Prudential
15 Mar 2021 ASF response to RBA fallbacks consultation

ASF response to RBA's request for feedback on BBSW fallbacks in RBA-eligible securities

Submission Benchmark reform, Regulatory and Prudential
14 Dec 2020 ASF Submission to NZ Treasury on Overseas Investment Bill 2020

This Submission focused on the proposed exemptions for financing transactions...

Submission New Zealand
22 Oct 2020 Submission on the third Consultation Document of Phase 2 of the Reserve Bank Act Review

A submission to Crown Treasury by the ASF's New Zealand market sub-committee...

Submission New Zealand
15 Jul 2020 Submission to the Reserve Bank of New Zealand on NZClear 2.0 factored securities functionality

Submission for the ASF New Zealand market sub-committee to the RBNZ outlining key functionality sought by the industry in NZClear.

Submission New Zealand
15 Jun 2020 Submission on Amendments to Overseas Investment Act and Regulations (NZ)

A submission by the ASF's New Zealand Market subcommittee to New Zealand’s Overseas Investment Office supporting the proposed changes and advocating that the changes will remove unintended costs and time delays for lenders and ensure an efficient flow of funds to borrowers without affecting the purpose of the OIO Act.
 

Submission New Zealand
23 Apr 2020 ASF NZ market subcommittee letter to the RBNZ regarding non-banks & COVID-19

A letter to the RBNZ highlighting some of the issues the New Zealand non-bank sector is facing as a direct result of COVID-19 and the resultant mandatory lockdown.

Submission New Zealand
23 Apr 2020 ASF NZ market subcommittee letter to NZ Ministry of Business regarding non-banks & COVID 19

A letter to the NZ Ministry of Business, Innovation and Employment requesting COVID-19 relief from the Credit Contracts and Consumer Finance Act 2003 for non-bank lenders.

Submission New Zealand
10 Mar 2020 ASF Submission to ASIC on product design & distribution obligations under the Corps Act

ASF submission to ASIC outlining the potential impact of matters contemplated in the DDO provisions, and the ASF’s recommendations to address the issues raised by this consultation.

Submission Regulatory and Prudential
03 Mar 2020 ASF Submission to ARNECC on proposed new VOI rules

ASF submission to the Australian Registrars National Electronic Conveyancing Council (ARNECC)’s consultation on its proposed new Verification of Identity (VOI) rules for mortgagees.
 

Submission Regulatory and Prudential
27 Feb 2020 Submission to the Reserve Bank of New Zealand on the NZClear clearing and settlements system

Submission from the ASF's New Zealand Market Subcommittee to the RBNZ highlighting some areas of concern with the new NZClear clearing & settlements system.

Submission New Zealand
24 Feb 2020 Submission to the Treasurer of Victoria on securitisation of equipment finance receivables

Submission to the Treasurer of Victoria (State Revenue Office) on the impact of the State Taxation Acts Amendment Act 2019 on securitisation of equipment finance receivables

Submission Taxation
24 Feb 2020 Submission to the Treasurer of WA on securitisation of equipment finance receivables

Submission to the Treasurer of Western Australia on the impact of the State Revenue Laws Amendment Act 2019 on securitisation of equipment finance receivables

Submission Taxation
06 Jun 2019 Submission on draft ABSF investment principles

Submission to AOFM on draft Australian Business Securitisation Fund investment principles

Submission ABSF and SFSF
31 May 2019 Letter on EFS data collection for SPVs

Letter to APRA on EFS data collection - proposed changes to reporting consolidation for securitisation SPVs

Submission Regulatory and Prudential
06 Mar 2019 Submission on ABSF proposed legislation (SELC)

Submission to Senate Economics Legislation Committee on Australian Business Securitisation Fund proposed legislation

Submission ABSF and SFSF
04 Feb 2019 Submission on Phase 2 of the Reserve Bank Act Review

Submission to New Zealand Treasury's consultation 'Phase 2 of the Reserve Bank Act Review: Safeguarding the future of our financial system

Submission New Zealand
28 Jan 2019 Submission on Japan's proposed securitisation regulations (English version)

Submission to Japanese Financial Services Agency's consultation on proposed securitisation regulations

Submission Japan
16 Jan 2019 Submission on ABSF proposed legislation (Treasury)

Submission to Treasury on Australian Business Securitisation Fund proposed legislation

Submission ABSF and SFSF