Date | Title & Summary | Topic Area | Sent to |
---|---|---|---|
23-Dec-2016 | Diverted Profits Tax Exposure DraftSubmission detailing potential impacts of the DPT on financial markets participants and the proposal to include the DPT in Part IVA. |
Taxation | Treasury |
19-Dec-2016 | Proposed Industry Funding Model for ASIC – Submission to the Second ConsultationSubmission to Treasury consultation following on from previous submissions that continues to press for appropriate accountability and transparency arrangements. The submission also details problems with the proposed levy arrangements for investment banks, entities that trade in OTC financial products, and message based charges for futures and derivatives transactions. |
Regulation | Treasury |
09-Dec-2016 | Regulator Performance FrameworkResponse to ASIC request for feedback. |
Regulation | ASIC |
09-Dec-2016 | Privacy implications re collection of KYC information from sources other than the customerComments on the draft Privacy Guidance for collecting KYC information, in particular that the guidance will impose significant restrictions on the ability of reporting entities to use the optional procedure to collect information. |
Regulation | AUSTRAC |
05-Dec-2016 | ASIC Consultation Paper 268 – Licensing relief for foreign financial service providers with a limited connection to AustraliaSubmission arguing that CO 03/824 relief should not be repealed as it continues to serve an important regulatory purpose, and the Corporations Regulations are not a complete substitute for the relief provided by the class order. The scope and purpose of the class order should be clarified as needed to achieve ASIC’s regulatory aims. |
Regulation | ASIC |
02-Dec-2016 | CPS 226 Margin requirements for non-centrally cleared derivativesSubmission on a number of definitional and technical issues in CPS 226. |
Regulation | APRA |
11-Nov-2016 | Replacement of CHESS for equity post-trade servicesSubmission to the ASX consultation paper on business requirements for the replacement of CHESS |
Other | ASX |
11-Nov-2016 | AML/CTF Act reviewSubmission in relation to the draft project plan for implementation of the recommendations of the statutory review of the AML/CTF regime |
Regulation | Attorney General's Department |
31-Oct-2016 | National Guarantee Fund reform proposalSubmission on options for reform of the NGF including the heads of claim. |
Other | SEGC |
28-Oct-2016 | Draft Prudential Standard 210 and Prudential Practice Guide APG 210 – LiquiditySubmission in relation to the treatment of open reverse repo transactions in the Net Stable Funding Ratio, offshore back offices, and the liquid asset requirements for foreign ADIs. |
Regulation | APRA |
28-Oct-2016 | Banks international exposures reportingSubmission to the APRA discussion paper noting the system upgrades and cost, the difficulty of meeting the implementation date, and the need to co-ordinate with other changes requiring additional reporting. |
Regulation | APRA |
10-Oct-2016 | Review of the financial system external dispute resolution frameworkAFMA submission seeking alignment of the EDR framework with the Corporations Act provisions re the treatment of wholesale clients. |
Regulation | Treasury |
10-Oct-2016 | RBA RITS Regulation rewriteSubmission in relation to the requirement to notify about change of jurisdiction of incorporation, RBA failure to notify certain matters, and definitional issues. |
Regulation | RBA |
30-Sep-2016 | Framework for concerted practices guidelinesAFMA submission on areas that would benefit from additional ACCC guidance. |
Regulation | ACCC |
30-Sep-2016 | Significant Global Entities Lodging General Purpose Financial Statements ATO Discussion PaperSubmission focusing on the issues arising for AFMA members that are headquartered outside of Australia, particularly those that operate in Australia through a permanent establishment as opposed to a separately Australian incorporated entity. |
Taxation | ATO |
29-Sep-2016 | ASX interest rate derivatives clearingAFMA submission to ASX consultation paper on interest rate derivatives clearing |
Regulation | ASX |
23-Sep-2016 | Treasury Laws Amendment (Enterprise Tax Plan) Bill 2016Submission supporting the proposed phased-in reduction of Australia’s corporate tax rate to 25% for all corporates over a ten-year horizon. |
Taxation | Senate Standing Committee on Economics |
15-Sep-2016 | FICC Markets Standards Board draft transparency standardsAFMA submission on draft transparency standards for reference price transactions and binary options in commodities markets. |
Regulation | UK FICC Markets Standards Board |
23-Aug-2016 | Derivatives Transaction Rules (Reporting) 2013Submission seeking extension of existing relief under the DTRs for FX securities conversion transactions and for entity information and name information. |
Regulation | ASIC |
15-Aug-2016 | ASX clearing participant minimum core capital requirementsSubmission in support of additional capital requirements for own-account business, non-ASX business and client short ETO activity. |
Regulation | ASX |
29-Jul-2016 | Submission to Productivity Commission Inquiry into Data Availability and UseThis submission discusses the efficiency of public and private data provision and its use with particular reference to the role of financial markets in the Australian economy. It notes that the data currently collected on financial markets by regulators can be used more effectively. The submission also suggests some low cost ways in which government legislation and spending could be made more transparent, facilitating improved public policy. |
Regulation | Productivity Commission |
07-Jul-2016 | Draft costings: electronic safe harbour proceduresFurther AFMA submission on proposed amendments to Chapter 4 of the AML/CTF Rules to align the electronic safe harbour procedures for customers with those for beneficial owners. AFMA remains supportive of the proposed amendments to the Rules and believes that over the medium to long term they will result in deregulation savings. However, given uncertainty about the quantification of the projected annual savings, we do not support any purported deregulation savings as being used as an offset for additional regulatory burden being imposed on AFMA members in the future |
Regulation | AUSTRAC |
06-Jul-2016 | Admission requirements for listed entitiesAFMA submission supporting proposed changes to the ASX listings standards which are critical to the integrity of equity exchange markets and the trust and confidence investors have in them. A key area of responsibility for exchanges is determining what instruments to admit to trading and the basis on which to admit them. The International Organization of Securities Commissions (IOSCO) Objectives and principles of securities regulation states that admission standards for issuers and participants are to be robust and administered in a fair and transparent way. ASX under the market operator provisions of the Corporation Act has a statutory obligation to robustly administer the qualification process for listing, and ensure listed entities meet their ongoing obligations to investors under the listing rules. |
Regulation | ASX |
30-Jun-2016 | Client money provisions and margining requirements for wholesale OTC derivativesIndustry submission seeking adjustments to the client money provisions in the Corporations Act so that the margining framework for non-cleared derivatives developed by BCBS-IOSCO functions properly for Australian market participants. |
Regulation | Treasury |
24-Jun-2016 | Diverted profits taxAFMA submission to Treasury discussion paper about implementing a diverted profits tax. |
Taxation | Treasury |
10-Jun-2016 | AUSTRAC FY 2016/17 industry contributionAFMA submission on revisions to the industry charging model. |
Regulation | AUSTRAC |
07-Jun-2016 | Draft amendments to Chapter 22 of the AML/CTF RulesAFMA comments on proposed amendments to the existing Chapter 22 exemption for certain participants in the energy derivatives markets. |
Regulation | AUSTRAC |
03-Jun-2016 | GST treatment of digital currencyAFMA submission to Treasury discussion paper on how digital currency should be treated for GST purposes. |
Taxation | Treasury |
30-May-2016 | Indicator Lending RateAFMA feedback on the ATO’s Technical Discussion Paper titled “Income tax: what is the Indicator Lending Rate applicable under subsection 247-20(5) of Division 247 of Part 3-10 of the Income Tax Assessment Act 1997 and subsection 247-80(4) of Division 247 in Part 3-10 of the Income Tax (Transitional Borrowings) Act 1997 in respect of capital protected borrowings (CPBs)?” and the accompanying Draft Taxation Determination |
Taxation | ATO |
13-May-2016 | Exchange traded options (ETO) trade cancellationAFMA response to ASX consultation paper on the ETO trade cancellation regime |
Regulation | ASX |
13-May-2016 | Insolvency law and ‘ipso facto’ clausesAFMA response to National Innovation and Science Agenda – Improving Bankruptcy and Insolvency Law Proposals Paper |
Regulation | Treasury |
29-Apr-2016 | ASX clearing participants liquidity risk managementAFMA response to ASX consultation paper on clearing participants liquidity risk management framework |
Regulation | ASX |
22-Apr-2016 | Chi-X TraCRs and QMFsAFMA response to Chi-X consultation paper about the introduction of Transferable Custody Receipts and Quoted Managed Funds on the Chi-X market |
Regulation | Chi-X |
30-Mar-2016 | Multinational Anti Avoidance Law (MAAL)Submission to the ATO outlining the potential application of the MAAL to AFMA members who operate through either a foreign bank branch or subsidiary in Australia, and a request for a risk assessment |
Taxation | ATO |
29-Mar-2016 | Enhanced Protection of Client MoneyAFMA has made a submission on the Exposure Draft Corporation Amendment (Client Money) Bill 2016, Regulation and Explanatory Memorandum, in addition to the submission dated 10 February 2016 on broader client money issues |
Regulation | Treasury |
21-Mar-2016 | Joint AFMA/ISDA request for ASIC class order reliefAFMA and ISDA have jointly applied to ASIC for class order relief in relation to central clearing of swaps resulting from transactions in swaptions entered into prior to the clearing commencement date |
Regulation | ASIC |
11-Mar-2016 | Inquiry into the External Scrutiny of the Australian Taxation OfficeIn a submission to the House Standing Committee, AFMA has supported continuing robust governance and accountability arrangements for regulators and government agencies, including the ATO. |
Regulation | Standing Committee on Tax and Revenue |
29-Feb-2016 | Tax incentives for early stage investorsTax incentives for early stage investors |
Taxation | Treasury |
19-Feb-2016 | Special review second draft report – Australia’s climate policy optionsSpecial review second draft report – Australia’s climate policy options |
Other | Climate Change Authority |
10-Feb-2016 | Enhanced protection of client money policy paper - AnnexureEnhanced protection of client money policy paper - Annexure |
Regulation | Treasury |
10-Feb-2016 | Enhanced protection of client money policy paper - Cover LetterEnhanced protection of client money policy paper - Cover Letter |
Regulation | Treasury |
05-Feb-2016 | Resilience and collateral protection amendmentsResilience and collateral protection amendments |
Regulation | Treasury |
05-Feb-2016 | 2016-17 pre-budget submission2016-17 pre-budget submission |
Other | Treasury |
15-Jan-2016 | Inquiry into interest deductibilityInquiry into interest deductibility |
Taxation | Senate Standing Committee on Economics |
15-Jan-2016 | Commissioner of Taxation remedial powerCommissioner of Taxation remedial power |
Regulation | Treasury |
08-Jan-2016 | Joint AFMA/ISDA application for continuation of relief under ASIC Instrument 2015/844Joint AFMA/ISDA application for continuation of relief under ASIC Instrument 2015/844 in relation to the requirement to share and pair a universal transaction identifier from 1 Feb |
Regulation | ASIC |
Date | Title & Summary | Topic Area | Sent to |
---|---|---|---|
05-Feb-2016 | 2016-17 pre-budget submission2016-17 pre-budget submission |
Other | Treasury |
06-Jul-2016 | Admission requirements for listed entitiesAFMA submission supporting proposed changes to the ASX listings standards which are critical to the integrity of equity exchange markets and the trust and confidence investors have in them. A key area of responsibility for exchanges is determining what instruments to admit to trading and the basis on which to admit them. The International Organization of Securities Commissions (IOSCO) Objectives and principles of securities regulation states that admission standards for issuers and participants are to be robust and administered in a fair and transparent way. ASX under the market operator provisions of the Corporation Act has a statutory obligation to robustly administer the qualification process for listing, and ensure listed entities meet their ongoing obligations to investors under the listing rules. |
Regulation | ASX |
11-Nov-2016 | AML/CTF Act reviewSubmission in relation to the draft project plan for implementation of the recommendations of the statutory review of the AML/CTF regime |
Regulation | Attorney General's Department |
05-Dec-2016 | ASIC Consultation Paper 268 – Licensing relief for foreign financial service providers with a limited connection to AustraliaSubmission arguing that CO 03/824 relief should not be repealed as it continues to serve an important regulatory purpose, and the Corporations Regulations are not a complete substitute for the relief provided by the class order. The scope and purpose of the class order should be clarified as needed to achieve ASIC’s regulatory aims. |
Regulation | ASIC |
15-Aug-2016 | ASX clearing participant minimum core capital requirementsSubmission in support of additional capital requirements for own-account business, non-ASX business and client short ETO activity. |
Regulation | ASX |
29-Apr-2016 | ASX clearing participants liquidity risk managementAFMA response to ASX consultation paper on clearing participants liquidity risk management framework |
Regulation | ASX |
29-Sep-2016 | ASX interest rate derivatives clearingAFMA submission to ASX consultation paper on interest rate derivatives clearing |
Regulation | ASX |
10-Jun-2016 | AUSTRAC FY 2016/17 industry contributionAFMA submission on revisions to the industry charging model. |
Regulation | AUSTRAC |
28-Oct-2016 | Banks international exposures reportingSubmission to the APRA discussion paper noting the system upgrades and cost, the difficulty of meeting the implementation date, and the need to co-ordinate with other changes requiring additional reporting. |
Regulation | APRA |
22-Apr-2016 | Chi-X TraCRs and QMFsAFMA response to Chi-X consultation paper about the introduction of Transferable Custody Receipts and Quoted Managed Funds on the Chi-X market |
Regulation | Chi-X |
30-Jun-2016 | Client money provisions and margining requirements for wholesale OTC derivativesIndustry submission seeking adjustments to the client money provisions in the Corporations Act so that the margining framework for non-cleared derivatives developed by BCBS-IOSCO functions properly for Australian market participants. |
Regulation | Treasury |
15-Jan-2016 | Commissioner of Taxation remedial powerCommissioner of Taxation remedial power |
Regulation | Treasury |
02-Dec-2016 | CPS 226 Margin requirements for non-centrally cleared derivativesSubmission on a number of definitional and technical issues in CPS 226. |
Regulation | APRA |
23-Aug-2016 | Derivatives Transaction Rules (Reporting) 2013Submission seeking extension of existing relief under the DTRs for FX securities conversion transactions and for entity information and name information. |
Regulation | ASIC |
24-Jun-2016 | Diverted profits taxAFMA submission to Treasury discussion paper about implementing a diverted profits tax. |
Taxation | Treasury |
23-Dec-2016 | Diverted Profits Tax Exposure DraftSubmission detailing potential impacts of the DPT on financial markets participants and the proposal to include the DPT in Part IVA. |
Taxation | Treasury |
07-Jun-2016 | Draft amendments to Chapter 22 of the AML/CTF RulesAFMA comments on proposed amendments to the existing Chapter 22 exemption for certain participants in the energy derivatives markets. |
Regulation | AUSTRAC |
07-Jul-2016 | Draft costings: electronic safe harbour proceduresFurther AFMA submission on proposed amendments to Chapter 4 of the AML/CTF Rules to align the electronic safe harbour procedures for customers with those for beneficial owners. AFMA remains supportive of the proposed amendments to the Rules and believes that over the medium to long term they will result in deregulation savings. However, given uncertainty about the quantification of the projected annual savings, we do not support any purported deregulation savings as being used as an offset for additional regulatory burden being imposed on AFMA members in the future |
Regulation | AUSTRAC |
28-Oct-2016 | Draft Prudential Standard 210 and Prudential Practice Guide APG 210 – LiquiditySubmission in relation to the treatment of open reverse repo transactions in the Net Stable Funding Ratio, offshore back offices, and the liquid asset requirements for foreign ADIs. |
Regulation | APRA |
29-Mar-2016 | Enhanced Protection of Client MoneyAFMA has made a submission on the Exposure Draft Corporation Amendment (Client Money) Bill 2016, Regulation and Explanatory Memorandum, in addition to the submission dated 10 February 2016 on broader client money issues |
Regulation | Treasury |
10-Feb-2016 | Enhanced protection of client money policy paper - AnnexureEnhanced protection of client money policy paper - Annexure |
Regulation | Treasury |
10-Feb-2016 | Enhanced protection of client money policy paper - Cover LetterEnhanced protection of client money policy paper - Cover Letter |
Regulation | Treasury |
13-May-2016 | Exchange traded options (ETO) trade cancellationAFMA response to ASX consultation paper on the ETO trade cancellation regime |
Regulation | ASX |
15-Sep-2016 | FICC Markets Standards Board draft transparency standardsAFMA submission on draft transparency standards for reference price transactions and binary options in commodities markets. |
Regulation | UK FICC Markets Standards Board |
30-Sep-2016 | Framework for concerted practices guidelinesAFMA submission on areas that would benefit from additional ACCC guidance. |
Regulation | ACCC |
03-Jun-2016 | GST treatment of digital currencyAFMA submission to Treasury discussion paper on how digital currency should be treated for GST purposes. |
Taxation | Treasury |
30-May-2016 | Indicator Lending RateAFMA feedback on the ATO’s Technical Discussion Paper titled “Income tax: what is the Indicator Lending Rate applicable under subsection 247-20(5) of Division 247 of Part 3-10 of the Income Tax Assessment Act 1997 and subsection 247-80(4) of Division 247 in Part 3-10 of the Income Tax (Transitional Borrowings) Act 1997 in respect of capital protected borrowings (CPBs)?” and the accompanying Draft Taxation Determination |
Taxation | ATO |
15-Jan-2016 | Inquiry into interest deductibilityInquiry into interest deductibility |
Taxation | Senate Standing Committee on Economics |
11-Mar-2016 | Inquiry into the External Scrutiny of the Australian Taxation OfficeIn a submission to the House Standing Committee, AFMA has supported continuing robust governance and accountability arrangements for regulators and government agencies, including the ATO. |
Regulation | Standing Committee on Tax and Revenue |
13-May-2016 | Insolvency law and ‘ipso facto’ clausesAFMA response to National Innovation and Science Agenda – Improving Bankruptcy and Insolvency Law Proposals Paper |
Regulation | Treasury |
08-Jan-2016 | Joint AFMA/ISDA application for continuation of relief under ASIC Instrument 2015/844Joint AFMA/ISDA application for continuation of relief under ASIC Instrument 2015/844 in relation to the requirement to share and pair a universal transaction identifier from 1 Feb |
Regulation | ASIC |
21-Mar-2016 | Joint AFMA/ISDA request for ASIC class order reliefAFMA and ISDA have jointly applied to ASIC for class order relief in relation to central clearing of swaps resulting from transactions in swaptions entered into prior to the clearing commencement date |
Regulation | ASIC |
30-Mar-2016 | Multinational Anti Avoidance Law (MAAL)Submission to the ATO outlining the potential application of the MAAL to AFMA members who operate through either a foreign bank branch or subsidiary in Australia, and a request for a risk assessment |
Taxation | ATO |
31-Oct-2016 | National Guarantee Fund reform proposalSubmission on options for reform of the NGF including the heads of claim. |
Other | SEGC |
09-Dec-2016 | Privacy implications re collection of KYC information from sources other than the customerComments on the draft Privacy Guidance for collecting KYC information, in particular that the guidance will impose significant restrictions on the ability of reporting entities to use the optional procedure to collect information. |
Regulation | AUSTRAC |
19-Dec-2016 | Proposed Industry Funding Model for ASIC – Submission to the Second ConsultationSubmission to Treasury consultation following on from previous submissions that continues to press for appropriate accountability and transparency arrangements. The submission also details problems with the proposed levy arrangements for investment banks, entities that trade in OTC financial products, and message based charges for futures and derivatives transactions. |
Regulation | Treasury |
10-Oct-2016 | RBA RITS Regulation rewriteSubmission in relation to the requirement to notify about change of jurisdiction of incorporation, RBA failure to notify certain matters, and definitional issues. |
Regulation | RBA |
09-Dec-2016 | Regulator Performance FrameworkResponse to ASIC request for feedback. |
Regulation | ASIC |
11-Nov-2016 | Replacement of CHESS for equity post-trade servicesSubmission to the ASX consultation paper on business requirements for the replacement of CHESS |
Other | ASX |
05-Feb-2016 | Resilience and collateral protection amendmentsResilience and collateral protection amendments |
Regulation | Treasury |
10-Oct-2016 | Review of the financial system external dispute resolution frameworkAFMA submission seeking alignment of the EDR framework with the Corporations Act provisions re the treatment of wholesale clients. |
Regulation | Treasury |
30-Sep-2016 | Significant Global Entities Lodging General Purpose Financial Statements ATO Discussion PaperSubmission focusing on the issues arising for AFMA members that are headquartered outside of Australia, particularly those that operate in Australia through a permanent establishment as opposed to a separately Australian incorporated entity. |
Taxation | ATO |
19-Feb-2016 | Special review second draft report – Australia’s climate policy optionsSpecial review second draft report – Australia’s climate policy options |
Other | Climate Change Authority |
29-Jul-2016 | Submission to Productivity Commission Inquiry into Data Availability and UseThis submission discusses the efficiency of public and private data provision and its use with particular reference to the role of financial markets in the Australian economy. It notes that the data currently collected on financial markets by regulators can be used more effectively. The submission also suggests some low cost ways in which government legislation and spending could be made more transparent, facilitating improved public policy. |
Regulation | Productivity Commission |
29-Feb-2016 | Tax incentives for early stage investorsTax incentives for early stage investors |
Taxation | Treasury |
23-Sep-2016 | Treasury Laws Amendment (Enterprise Tax Plan) Bill 2016Submission supporting the proposed phased-in reduction of Australia’s corporate tax rate to 25% for all corporates over a ten-year horizon. |
Taxation | Senate Standing Committee on Economics |
Date | Title & Summary | Topic Area | Sent to |
---|---|---|---|
05-Feb-2016 | 2016-17 pre-budget submission2016-17 pre-budget submission |
Other | Treasury |
06-Jul-2016 | Admission requirements for listed entitiesAFMA submission supporting proposed changes to the ASX listings standards which are critical to the integrity of equity exchange markets and the trust and confidence investors have in them. A key area of responsibility for exchanges is determining what instruments to admit to trading and the basis on which to admit them. The International Organization of Securities Commissions (IOSCO) Objectives and principles of securities regulation states that admission standards for issuers and participants are to be robust and administered in a fair and transparent way. ASX under the market operator provisions of the Corporation Act has a statutory obligation to robustly administer the qualification process for listing, and ensure listed entities meet their ongoing obligations to investors under the listing rules. |
Regulation | ASX |
11-Nov-2016 | AML/CTF Act reviewSubmission in relation to the draft project plan for implementation of the recommendations of the statutory review of the AML/CTF regime |
Regulation | Attorney General's Department |
05-Dec-2016 | ASIC Consultation Paper 268 – Licensing relief for foreign financial service providers with a limited connection to AustraliaSubmission arguing that CO 03/824 relief should not be repealed as it continues to serve an important regulatory purpose, and the Corporations Regulations are not a complete substitute for the relief provided by the class order. The scope and purpose of the class order should be clarified as needed to achieve ASIC’s regulatory aims. |
Regulation | ASIC |
15-Aug-2016 | ASX clearing participant minimum core capital requirementsSubmission in support of additional capital requirements for own-account business, non-ASX business and client short ETO activity. |
Regulation | ASX |
29-Apr-2016 | ASX clearing participants liquidity risk managementAFMA response to ASX consultation paper on clearing participants liquidity risk management framework |
Regulation | ASX |
29-Sep-2016 | ASX interest rate derivatives clearingAFMA submission to ASX consultation paper on interest rate derivatives clearing |
Regulation | ASX |
10-Jun-2016 | AUSTRAC FY 2016/17 industry contributionAFMA submission on revisions to the industry charging model. |
Regulation | AUSTRAC |
28-Oct-2016 | Banks international exposures reportingSubmission to the APRA discussion paper noting the system upgrades and cost, the difficulty of meeting the implementation date, and the need to co-ordinate with other changes requiring additional reporting. |
Regulation | APRA |
22-Apr-2016 | Chi-X TraCRs and QMFsAFMA response to Chi-X consultation paper about the introduction of Transferable Custody Receipts and Quoted Managed Funds on the Chi-X market |
Regulation | Chi-X |
30-Jun-2016 | Client money provisions and margining requirements for wholesale OTC derivativesIndustry submission seeking adjustments to the client money provisions in the Corporations Act so that the margining framework for non-cleared derivatives developed by BCBS-IOSCO functions properly for Australian market participants. |
Regulation | Treasury |
15-Jan-2016 | Commissioner of Taxation remedial powerCommissioner of Taxation remedial power |
Regulation | Treasury |
02-Dec-2016 | CPS 226 Margin requirements for non-centrally cleared derivativesSubmission on a number of definitional and technical issues in CPS 226. |
Regulation | APRA |
23-Aug-2016 | Derivatives Transaction Rules (Reporting) 2013Submission seeking extension of existing relief under the DTRs for FX securities conversion transactions and for entity information and name information. |
Regulation | ASIC |
24-Jun-2016 | Diverted profits taxAFMA submission to Treasury discussion paper about implementing a diverted profits tax. |
Taxation | Treasury |
23-Dec-2016 | Diverted Profits Tax Exposure DraftSubmission detailing potential impacts of the DPT on financial markets participants and the proposal to include the DPT in Part IVA. |
Taxation | Treasury |
07-Jun-2016 | Draft amendments to Chapter 22 of the AML/CTF RulesAFMA comments on proposed amendments to the existing Chapter 22 exemption for certain participants in the energy derivatives markets. |
Regulation | AUSTRAC |
07-Jul-2016 | Draft costings: electronic safe harbour proceduresFurther AFMA submission on proposed amendments to Chapter 4 of the AML/CTF Rules to align the electronic safe harbour procedures for customers with those for beneficial owners. AFMA remains supportive of the proposed amendments to the Rules and believes that over the medium to long term they will result in deregulation savings. However, given uncertainty about the quantification of the projected annual savings, we do not support any purported deregulation savings as being used as an offset for additional regulatory burden being imposed on AFMA members in the future |
Regulation | AUSTRAC |
28-Oct-2016 | Draft Prudential Standard 210 and Prudential Practice Guide APG 210 – LiquiditySubmission in relation to the treatment of open reverse repo transactions in the Net Stable Funding Ratio, offshore back offices, and the liquid asset requirements for foreign ADIs. |
Regulation | APRA |
29-Mar-2016 | Enhanced Protection of Client MoneyAFMA has made a submission on the Exposure Draft Corporation Amendment (Client Money) Bill 2016, Regulation and Explanatory Memorandum, in addition to the submission dated 10 February 2016 on broader client money issues |
Regulation | Treasury |
10-Feb-2016 | Enhanced protection of client money policy paper - AnnexureEnhanced protection of client money policy paper - Annexure |
Regulation | Treasury |
10-Feb-2016 | Enhanced protection of client money policy paper - Cover LetterEnhanced protection of client money policy paper - Cover Letter |
Regulation | Treasury |
13-May-2016 | Exchange traded options (ETO) trade cancellationAFMA response to ASX consultation paper on the ETO trade cancellation regime |
Regulation | ASX |
15-Sep-2016 | FICC Markets Standards Board draft transparency standardsAFMA submission on draft transparency standards for reference price transactions and binary options in commodities markets. |
Regulation | UK FICC Markets Standards Board |
30-Sep-2016 | Framework for concerted practices guidelinesAFMA submission on areas that would benefit from additional ACCC guidance. |
Regulation | ACCC |
03-Jun-2016 | GST treatment of digital currencyAFMA submission to Treasury discussion paper on how digital currency should be treated for GST purposes. |
Taxation | Treasury |
30-May-2016 | Indicator Lending RateAFMA feedback on the ATO’s Technical Discussion Paper titled “Income tax: what is the Indicator Lending Rate applicable under subsection 247-20(5) of Division 247 of Part 3-10 of the Income Tax Assessment Act 1997 and subsection 247-80(4) of Division 247 in Part 3-10 of the Income Tax (Transitional Borrowings) Act 1997 in respect of capital protected borrowings (CPBs)?” and the accompanying Draft Taxation Determination |
Taxation | ATO |
15-Jan-2016 | Inquiry into interest deductibilityInquiry into interest deductibility |
Taxation | Senate Standing Committee on Economics |
11-Mar-2016 | Inquiry into the External Scrutiny of the Australian Taxation OfficeIn a submission to the House Standing Committee, AFMA has supported continuing robust governance and accountability arrangements for regulators and government agencies, including the ATO. |
Regulation | Standing Committee on Tax and Revenue |
13-May-2016 | Insolvency law and ‘ipso facto’ clausesAFMA response to National Innovation and Science Agenda – Improving Bankruptcy and Insolvency Law Proposals Paper |
Regulation | Treasury |
08-Jan-2016 | Joint AFMA/ISDA application for continuation of relief under ASIC Instrument 2015/844Joint AFMA/ISDA application for continuation of relief under ASIC Instrument 2015/844 in relation to the requirement to share and pair a universal transaction identifier from 1 Feb |
Regulation | ASIC |
21-Mar-2016 | Joint AFMA/ISDA request for ASIC class order reliefAFMA and ISDA have jointly applied to ASIC for class order relief in relation to central clearing of swaps resulting from transactions in swaptions entered into prior to the clearing commencement date |
Regulation | ASIC |
30-Mar-2016 | Multinational Anti Avoidance Law (MAAL)Submission to the ATO outlining the potential application of the MAAL to AFMA members who operate through either a foreign bank branch or subsidiary in Australia, and a request for a risk assessment |
Taxation | ATO |
31-Oct-2016 | National Guarantee Fund reform proposalSubmission on options for reform of the NGF including the heads of claim. |
Other | SEGC |
09-Dec-2016 | Privacy implications re collection of KYC information from sources other than the customerComments on the draft Privacy Guidance for collecting KYC information, in particular that the guidance will impose significant restrictions on the ability of reporting entities to use the optional procedure to collect information. |
Regulation | AUSTRAC |
19-Dec-2016 | Proposed Industry Funding Model for ASIC – Submission to the Second ConsultationSubmission to Treasury consultation following on from previous submissions that continues to press for appropriate accountability and transparency arrangements. The submission also details problems with the proposed levy arrangements for investment banks, entities that trade in OTC financial products, and message based charges for futures and derivatives transactions. |
Regulation | Treasury |
10-Oct-2016 | RBA RITS Regulation rewriteSubmission in relation to the requirement to notify about change of jurisdiction of incorporation, RBA failure to notify certain matters, and definitional issues. |
Regulation | RBA |
09-Dec-2016 | Regulator Performance FrameworkResponse to ASIC request for feedback. |
Regulation | ASIC |
11-Nov-2016 | Replacement of CHESS for equity post-trade servicesSubmission to the ASX consultation paper on business requirements for the replacement of CHESS |
Other | ASX |
05-Feb-2016 | Resilience and collateral protection amendmentsResilience and collateral protection amendments |
Regulation | Treasury |
10-Oct-2016 | Review of the financial system external dispute resolution frameworkAFMA submission seeking alignment of the EDR framework with the Corporations Act provisions re the treatment of wholesale clients. |
Regulation | Treasury |
30-Sep-2016 | Significant Global Entities Lodging General Purpose Financial Statements ATO Discussion PaperSubmission focusing on the issues arising for AFMA members that are headquartered outside of Australia, particularly those that operate in Australia through a permanent establishment as opposed to a separately Australian incorporated entity. |
Taxation | ATO |
19-Feb-2016 | Special review second draft report – Australia’s climate policy optionsSpecial review second draft report – Australia’s climate policy options |
Other | Climate Change Authority |
29-Jul-2016 | Submission to Productivity Commission Inquiry into Data Availability and UseThis submission discusses the efficiency of public and private data provision and its use with particular reference to the role of financial markets in the Australian economy. It notes that the data currently collected on financial markets by regulators can be used more effectively. The submission also suggests some low cost ways in which government legislation and spending could be made more transparent, facilitating improved public policy. |
Regulation | Productivity Commission |
29-Feb-2016 | Tax incentives for early stage investorsTax incentives for early stage investors |
Taxation | Treasury |
23-Sep-2016 | Treasury Laws Amendment (Enterprise Tax Plan) Bill 2016Submission supporting the proposed phased-in reduction of Australia’s corporate tax rate to 25% for all corporates over a ten-year horizon. |
Taxation | Senate Standing Committee on Economics |