Submissions 2016

Date	Title & Summary	Topic Area	Sent to
23-Dec-2016	Diverted Profits Tax Exposure Draft Submission 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 Consultation Submission 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 Framework Response to ASIC request for feedback.	Regulation	ASIC
09-Dec-2016	Privacy implications re collection of KYC information from sources other than the customer Comments 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service providers with a limited connection to Australia Submission arguing that CO 03/824 relief should not be repealed as it continues to serve an important regulatory purpose, and the Corporations Regulations are not a complete substitute for the relief provided by the class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 derivatives Submission on a number of definitional and technical issues in CPS 226.	Regulation	APRA
11-Nov-2016	Replacement of CHESS for equity post-trade services Submission to the ASX consultation paper on business requirements for the replacement of CHESS	Other	ASX
11-Nov-2016	AML/CTF Act review Submission 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 proposal Submission 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 – Liquidity Submission 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 reporting Submission 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 framework AFMA 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 rewrite Submission 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 guidelines AFMA 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 Paper Submission 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 clearing AFMA submission to ASX consultation paper on interest rate derivatives clearing	Regulation	ASX
23-Sep-2016	Treasury Laws Amendment (Enterprise Tax Plan) Bill 2016 Submission 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 standards AFMA 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) 2013 Submission 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 requirements Submission 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 Use This 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 procedures Further 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 entities AFMA 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 derivatives Industry 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 tax AFMA submission to Treasury discussion paper about implementing a diverted profits tax.	Taxation	Treasury
10-Jun-2016	AUSTRAC FY 2016/17 industry contribution AFMA submission on revisions to the industry charging model.	Regulation	AUSTRAC
07-Jun-2016	Draft amendments to Chapter 22 of the AML/CTF Rules AFMA 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 currency AFMA submission to Treasury discussion paper on how digital currency should be treated for GST purposes.	Taxation	Treasury
30-May-2016	Indicator Lending Rate AFMA 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 cancellation AFMA response to ASX consultation paper on the ETO trade cancellation regime	Regulation	ASX
13-May-2016	Insolvency law and ‘ipso facto’ clauses AFMA response to National Innovation and Science Agenda – Improving Bankruptcy and Insolvency Law Proposals Paper	Regulation	Treasury
29-Apr-2016	ASX clearing participants liquidity risk management AFMA response to ASX consultation paper on clearing participants liquidity risk management framework	Regulation	ASX
22-Apr-2016	Chi-X TraCRs and QMFs AFMA 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 Money AFMA 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 relief AFMA 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 Office In 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 investors Tax incentives for early stage investors	Taxation	Treasury
19-Feb-2016	Special review second draft report – Australia’s climate policy options Special review second draft report – Australia’s climate policy options	Other	Climate Change Authority
10-Feb-2016	Enhanced protection of client money policy paper - Annexure Enhanced protection of client money policy paper - Annexure	Regulation	Treasury
10-Feb-2016	Enhanced protection of client money policy paper - Cover Letter Enhanced protection of client money policy paper - Cover Letter	Regulation	Treasury
05-Feb-2016	Resilience and collateral protection amendments Resilience and collateral protection amendments	Regulation	Treasury
05-Feb-2016	2016-17 pre-budget submission 2016-17 pre-budget submission	Other	Treasury
15-Jan-2016	Inquiry into interest deductibility Inquiry into interest deductibility	Taxation	Senate Standing Committee on Economics
15-Jan-2016	Commissioner of Taxation remedial power Commissioner of Taxation remedial power	Regulation	Treasury
08-Jan-2016	Joint AFMA/ISDA application for continuation of relief under ASIC Instrument 2015/844 Joint 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 submission 2016-17 pre-budget submission	Other	Treasury
06-Jul-2016	Admission requirements for listed entities AFMA 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 review Submission 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 Australia Submission 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 requirements Submission 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 management AFMA response to ASX consultation paper on clearing participants liquidity risk management framework	Regulation	ASX
29-Sep-2016	ASX interest rate derivatives clearing AFMA submission to ASX consultation paper on interest rate derivatives clearing	Regulation	ASX
10-Jun-2016	AUSTRAC FY 2016/17 industry contribution AFMA submission on revisions to the industry charging model.	Regulation	AUSTRAC
28-Oct-2016	Banks international exposures reporting Submission 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 QMFs AFMA 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 derivatives Industry 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 power Commissioner of Taxation remedial power	Regulation	Treasury
02-Dec-2016	CPS 226 Margin requirements for non-centrally cleared derivatives Submission on a number of definitional and technical issues in CPS 226.	Regulation	APRA
23-Aug-2016	Derivatives Transaction Rules (Reporting) 2013 Submission 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 tax AFMA submission to Treasury discussion paper about implementing a diverted profits tax.	Taxation	Treasury
23-Dec-2016	Diverted Profits Tax Exposure Draft Submission 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 Rules AFMA 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 procedures Further 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 – Liquidity Submission 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 Money AFMA 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 - Annexure Enhanced protection of client money policy paper - Annexure	Regulation	Treasury
10-Feb-2016	Enhanced protection of client money policy paper - Cover Letter Enhanced protection of client money policy paper - Cover Letter	Regulation	Treasury
13-May-2016	Exchange traded options (ETO) trade cancellation AFMA response to ASX consultation paper on the ETO trade cancellation regime	Regulation	ASX
15-Sep-2016	FICC Markets Standards Board draft transparency standards AFMA 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 guidelines AFMA submission on areas that would benefit from additional ACCC guidance.	Regulation	ACCC
03-Jun-2016	GST treatment of digital currency AFMA submission to Treasury discussion paper on how digital currency should be treated for GST purposes.	Taxation	Treasury
30-May-2016	Indicator Lending Rate AFMA 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 deductibility Inquiry into interest deductibility	Taxation	Senate Standing Committee on Economics
11-Mar-2016	Inquiry into the External Scrutiny of the Australian Taxation Office In 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’ clauses AFMA 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 2015/844 Joint 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 relief AFMA 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 proposal Submission 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 customer Comments 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 Consultation Submission 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 rewrite Submission 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 Framework Response to ASIC request for feedback.	Regulation	ASIC
11-Nov-2016	Replacement of CHESS for equity post-trade services Submission to the ASX consultation paper on business requirements for the replacement of CHESS	Other	ASX
05-Feb-2016	Resilience and collateral protection amendments Resilience and collateral protection amendments	Regulation	Treasury
10-Oct-2016	Review of the financial system external dispute resolution framework AFMA 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 Paper Submission 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 options Special 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 Use This 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 investors Tax incentives for early stage investors	Taxation	Treasury
23-Sep-2016	Treasury Laws Amendment (Enterprise Tax Plan) Bill 2016 Submission 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 submission 2016-17 pre-budget submission	Other	Treasury
06-Jul-2016	Admission requirements for listed entities AFMA 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 review Submission 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 Australia Submission 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 requirements Submission 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 management AFMA response to ASX consultation paper on clearing participants liquidity risk management framework	Regulation	ASX
29-Sep-2016	ASX interest rate derivatives clearing AFMA submission to ASX consultation paper on interest rate derivatives clearing	Regulation	ASX
10-Jun-2016	AUSTRAC FY 2016/17 industry contribution AFMA submission on revisions to the industry charging model.	Regulation	AUSTRAC
28-Oct-2016	Banks international exposures reporting Submission 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 QMFs AFMA 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 derivatives Industry 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 power Commissioner of Taxation remedial power	Regulation	Treasury
02-Dec-2016	CPS 226 Margin requirements for non-centrally cleared derivatives Submission on a number of definitional and technical issues in CPS 226.	Regulation	APRA
23-Aug-2016	Derivatives Transaction Rules (Reporting) 2013 Submission 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 tax AFMA submission to Treasury discussion paper about implementing a diverted profits tax.	Taxation	Treasury
23-Dec-2016	Diverted Profits Tax Exposure Draft Submission 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 Rules AFMA 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 procedures Further 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 – Liquidity Submission 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 Money AFMA 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 - Annexure Enhanced protection of client money policy paper - Annexure	Regulation	Treasury
10-Feb-2016	Enhanced protection of client money policy paper - Cover Letter Enhanced protection of client money policy paper - Cover Letter	Regulation	Treasury
13-May-2016	Exchange traded options (ETO) trade cancellation AFMA response to ASX consultation paper on the ETO trade cancellation regime	Regulation	ASX
15-Sep-2016	FICC Markets Standards Board draft transparency standards AFMA 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 guidelines AFMA submission on areas that would benefit from additional ACCC guidance.	Regulation	ACCC
03-Jun-2016	GST treatment of digital currency AFMA submission to Treasury discussion paper on how digital currency should be treated for GST purposes.	Taxation	Treasury
30-May-2016	Indicator Lending Rate AFMA 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 deductibility Inquiry into interest deductibility	Taxation	Senate Standing Committee on Economics
11-Mar-2016	Inquiry into the External Scrutiny of the Australian Taxation Office In 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’ clauses AFMA 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 2015/844 Joint 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 relief AFMA 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 proposal Submission 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 customer Comments 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 Consultation Submission 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 rewrite Submission 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 Framework Response to ASIC request for feedback.	Regulation	ASIC
11-Nov-2016	Replacement of CHESS for equity post-trade services Submission to the ASX consultation paper on business requirements for the replacement of CHESS	Other	ASX
05-Feb-2016	Resilience and collateral protection amendments Resilience and collateral protection amendments	Regulation	Treasury
10-Oct-2016	Review of the financial system external dispute resolution framework AFMA 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 Paper Submission 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 options Special 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 Use This 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 investors Tax incentives for early stage investors	Taxation	Treasury
23-Sep-2016	Treasury Laws Amendment (Enterprise Tax Plan) Bill 2016 Submission 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