The Bankers’ Association welcomes this opportunity to address the Committee. We are the banking industry’s representative association and our submission is made on behalf of our thirteen member banks.
We are very supportive of the Bill and believe it will do much to promote confident and informed participation in our financial markets and the strengthening of our capital markets.
We also commend the consultation process undertaken by officials to date. Effective consultation with stakeholders is critical to the success of the Bill and as you have already heard from other submitters it is imperative that it continues throughout the process of drafting and finalising regulations.
I want to quickly mention up front what we won’t be talking about today. Throughout the course of these hearings, many submitters have addressed the Committee on the liability provisions in the Bill. We agree with much of what you have already heard, particularly the comments made by our member banks, law firms and the Institute of Directors. As liability is an issue which has been well canvassed before you, I do not wish to specifically address the Committee further on the matter.
You’ve also heard our member banks address you today on the Bill’s derivatives regime and some key managed investments scheme provisions. I won’t speak to that material now, although I note that representatives from the Association and our member banks would be available to work with officials on technical details with the Committee’s permission if you consider that is desirable.
It remains for us to focus our presentation on two of the matters which we raised in our written submission:
- the licensing regime, and
- the Bill’s transitional arrangements