Submissions

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).

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

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

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).

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. 
 

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

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

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

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

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.
 

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.

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.

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.

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

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

Submission to AOFM on draft Australian Business Securitisation Fund investment principles

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

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

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

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

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

Submission to Treasury on Australian Business Securitisation Fund proposed legislation