The Australian Centre for Financial Studies (ACFS) welcomed the opportunity to support APRA’s Inquiry into proposed revisions to Prudential Standard APS 330 Public Disclosure.
In response to the recent request for submissions on the draft changes to the prudential standard, this submissions offers the following comments and suggestions. They focus primarily upon the risk and capital adequacy disclosures.
Recommendation 1: Banks should be required to provide APS 330 Public Disclosure information in a form which enable direct copying of the tabular data into a table format in spreadsheets and other software without need for further formatting.
Recommendation 2: APRA should provide on its website the historical and current disclosures of all ADIs in a form which is convenient for analysis and comparison across ADIs.
Recommendation 3: The required reporting time for publication of APS330 Public Disclosures should be significantly reduced from 40 days.
Recommendation 4: The required quarterly disclosures should be the same as required for the semi-annual disclosures (and possibly also for the annual disclosures).