Submissions

ASF submission in response to review into Small and Medium-sized Banks Issues Paper by the Council of Financial Regulators (CFR) in consultation with the Australian Competition and Consumer Commission (Issues Paper)

Response to European Commission's consultation on the functioning of the EU securitisation framework

ASF New Zealand market subcommittee submission to New Zealand Finance and Expenditure Committee Inquiry into banking competition...

ASF submission to Senate Standing Committees on Economics Inquiry into financial regulatory framework and home ownership

Reassessing the Case for Central Clearing of Bonds and Repos in Australia consultation paper – Australian Securitisation Forum response to the Council of Financial Regulators

Consumer Data Right (CDR) in non-bank lending – Consultation on CDR rules: consent and operational enhancement amendments – Australian Securitisation Forum response
 

Financial Stability Board (FSB) Evaluation of the Effects of the G20 Financial Regulatory Reforms on Securitisation – Consultation report 2 July 2024 – ASF Responses

Letter supporting the European Covered Bond Council (ECBC) statement to the EBA in response to EBA call for advice.

Submission by the Australian Securitisation Forum to the Senate Economics Legislation Committee Inquiry into the Taxation (Multinational—Global and Domestic Minimum Tax) Imposition Bill 2024 [Provisions] and related bills

A letter to Treasury summarising the meeting held with the ASF's tax working group on the matter of Pillar 2 legislation.

Letter requesting certain remedial
amendments to the taxation of securitisation transactions be addressed in the next tax Bill.

The ASF is a signatory to an AFME led joint association response to ESMA’s consultation which was submitted to ESMA (European Securities and Markets Authority) on 21 March.  The response elects for the adoption of Option C as a more efficient and expedient method of simplifying the disclosure and reporting requirements applicable to private securitisations (which includes Australian securitisation transactions).
 

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

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

Submission to the Attorney General's Department...

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

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.

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

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

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

 

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

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

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

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...

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 Treasury on Australian Business Securitisation Fund proposed legislation