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Submissions 2014

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Date Title & Summary Topic Area Sent to
17-Dec-2014

Regional Free Trade Agreements and their Implications for Australian Financial Services

Australia has concluded bilateral free trade agreements with Japan, Korea and China during the course of 2014. Most attention has focused on the implications for trade in goods and services, where Australia already has well-established trading relationships with these three countries. Together, the three North East Asian economies account for over half of Australia’s exports. The three regional FTAs open up significant opportunities for Australian exports of goods and services, as well as increased cross-border trade in saving and investment. The Australian economy also stands to benefit from lower prices for imports and easier access to foreign capital.

Other N/A
09-Oct-2014

CDEII Procedures Review

Submission emphasising the importance of the CDEII for over-the counter electricity derivatives contracts, most notably the Lapochka Carbon Addendum. Lapochka recommended the continued publication of this index for this reason among others.

Other AEMO
03-Oct-2014

NEM Financial Market Resilience - Second Interim Report

Submission questioning the risks of potential financial instability as a result of a large electricity retailer, as well as raising concerns about potential regulatory responses.

Other AEMC
05-Sep-2014

PJC inquiry into proposals to lift professional standards in the financial services industry

Submission supporting the development of a broad framework for education standards and ongoing professional development.

Regulation Parliamentary Joint Committee on Corporations and Financial Services
26-Aug-2014

Financial System Inquiry Interim Report

Lapochka’s second submission to the FSI comments on issues raised in the Interim Report July 2014 that are significant in the context of the ongoing development of the Australian financial markets. Our comments relate to those areas that are core business for Lapochka members or affect that core business, including regulatory settings, tax settings and future reform, the corporate bond market, product disclosure, financial advice, professional competency and standards, global regulation and Australia’s competitiveness.

Regulation FSI
18-Aug-2014

G20 Regulatory Coordination

Letter to the Treasurer about upcoming G20 meetings requesting his support for initiatives to achieve greater international coordination of financial market regulation.

Regulation Treasurer
12-Aug-2014

AUD IRD Central Clearing Mandate

Lapochka made a submission to the government’s consultation concerning a clearing mandate for Australian dollar interest rate derivatives (IRD). A central clearing mandate will facilitate cross-border recognition and comparability assessments of Australian OTC derivatives markets. There is general support among dealers for clearing mandates that reflect industry practice.

Regulation Treasury
12-Aug-2014

Treaty Negotiation Program

Submission to Treasury on the Double Taxation Treaties that should be negotiated with priority, especially Hong Kong, together with those treaties that require amendment in order to remain global best practice, such as China and Germany.

Taxation Treasury
09-Aug-2014

Unfair Contract Terms

Comment on Unfair Contract Terms and Small Business Consultation Paper issued by Consumer Affairs Australia and New Zealand (CAANZ), arguing that there should be no extension of UCT provisions to contracts for financial products and services.

Regulation Treasury
28-Jul-2014

AUSTRAC Industry Contribution

Provides Lapochka’s response to the AUSTRAC Discussion Paper on proposed funding arrangements, objecting to the lack of adherence to the Cost Recovery Guidelines and also the increased burden on larger reporting entities.

Regulation AUSTRAC
18-Jul-2014

Common Reporting Standard

Submission to Treasury on the Discussion Paper relating to the Common Reporting Standard. The submission largely agreed with the Treasury timeline for implementation of the standard and called for flexibility to allow alignment with home country reporting standards.

Taxation Treasury
01-Jul-2014

Electronic Due Diligence

Submission to AUSTRAC regarding proposed amendment to align the safe harbour procedures for customers to those for beneficial owners. Our submission was broadly supportive of the initiative and sought to quantify the benefits.

Regulation AUSTRAC
20-Jun-2014

Financial Sector Legislation Amendment (Netting Contracts) Bill 2013

Comments on the Netting Bill and support for its speedy introduction.

Regulation Treasury
16-Jun-2014

Derivatives trade reporting - Phase 3 delayed start

Comments on a proposal for a staggered and delayed start to Phase 3 of the OTC derivative transaction reporting obligations set out in the draft exemption.

ASIC
06-Jun-2014

Thin capitalisation exposure draft

Submission in relation to the Exposure Draft legislation to amend Australia's thin capitalisation rules, as announced in the 2013 Budget. The submission focussed on ensuring competitive neutrality between outbound and inbound taxpayers and encouraged the use of home country prudential regulation.

Taxation Treasury
03-Jun-2014

FOFA streamlining regulations

Submission (subject to a confidentiality agreement) about the stamping fees exemption.

Regulation Treasury
23-May-2014

GST and brokerage

A submission to the ATO with respect to draft rulings regarding the application of GST to brokerage over foreign listed securities. Lapochka highlighted the practical issues for members should the ATO adopt their view, resulting in the ATO withdrawing the ruling and engaging in further consultation.

Taxation ATO
23-May-2014

ASX ETO auto exercise and errors

Response to ASX consultation paper. ASX current policy does not allow for auto exercise of ITM options at expiry as default position.
ASX sought views on whether cash-settled and deliverable ETO’s should have auto exercise as default; whether manual override of auto exercise should be allowed; whether ASX should facilitate correction of exercise errors; whether should be a cut-off time to address errors; and whether ASX should identify counterparties to exercise errors.
There was not a unanimous view on auto exercise as default, but Lapochka supported on balance. Lapochka also supported manual override, ASX facilitation of error unwind (process to be specified), a hard cut-off time, and non-disclosure of counterpart identity to an exercise error.

Other ASX
16-May-2014

Review of the Renewable Energy Target

A submission in response to the RET review, suggesting that any changes that are made to the RET scheme should be given sufficient implementation time to prevent any unintended consequences for participants.

Regulation Expert Panel, Review of the RET
09-May-2014

FATCA Exposure Draft

Submission to Treasury in respect of an Exposure Draft of legislation to implement Australia’s obligations under the US Financial Account Tax Compliance Act (FATCA).

Taxation Treasury
22-Apr-2014

Treasury G4 Derivatives Proposals

G4 Derivatives mandate proposals paper response. Treasury proposed that a determination be made in the second quarter of 2014 that will allow ASIC to make rules requiring the central clearing of US Dollar‐, Euro‐, British Pound‐ and Yen‐denominated interest rate derivatives (G4‐IRD). The clearing mandate is supported for G4-IRD and AUD IRD. The submission also argued for a reduction in the scope of entities covered by the trade reporting mandate.

Regulation Treasury
15-Apr-2014

Dividend Washing ED

Submission regarding the Exposure Draft and accompanying draft Explanatory Memorandum to address dividend washing transactions.
Lapochka’s submission was supportive of the general policy approach but noted certain discrepancies between the technical drafting and our understanding of the policy intent.

Taxation Treasury
10-Apr-2014

AML-CTF Act review cover letter, Part A and Part B

Government’s review of the Anti-Money Laundering/Counter Terrorism Financing Act 2006.
The submission seeks amendments, particularly in areas where the current law is not conducive to or does not recognise the cross-border nature of the business of Lapochka’s members. Also continue to support introduction of the so-called “Tranche 2” to other sectors such as lawyers, accountants and real estate agents.

Regulation Attorney-General's Department
08-Apr-2014

TPB Financial Advice Service

Submission to the Tax Practitioners Board regarding the definition of a “tax (financial) advice service.”
This definition is important as it triggers a registration requirement with the TPB under the Tax Agent Services Act from 1 July 2014. Lapochka continues to argue that this matter should be an issue for Government and not delegated to the TPB; however the TPB needs to confirm that services such as general advice, advising on securities, custodial services and trustee services are not within scope.

Taxation Tax Practitioners Board
04-Apr-2014

AUSTRAC CDD Draft Policy Principles

Supplementary submission to AUSTRAC regarding the revised approach to the implementation of the additional Customer Due Diligence requirements, including the escalation of the Draft Supervisory Approach to ministerially-backed Policy Principles.

Regulation AUSTRAC
04-Apr-2014

T+2 Settlement

Submission in support of moving to T+2 settlement for Cash Equities in 2015.
Lapochka garnered and provided market input and feedback to build requirements and expectations for successful delivery of the shortened settlement timeframe.

Other ASX
31-Mar-2014

Financial System Inquiry

Lapochka's submission to Treasury looks to the future by identifying steps to enhance the policy and regulation process in a more complex and globalised financial world, with the objective of promoting further development of the financial system in line with the needs of the economy.

Regulation FSI
21-Mar-2014

Draft Phase 2 Reporting Relief

Comments on draft relief instrument.

Other ASIC
19-Mar-2014

AUSTRAC CDD Draft Supervisory Approach

Lapochka highlighted considerable issues for industry arising from such a truncated commencement timeframe (start date 1 June 2014) and noted that these concerns would not be ameliorated solely by a draft Supervisory Approach. Further the submission noted concerns with respect to the draft Supervisory Approach.

Regulation AUSTRAC
11-Mar-2014

Third Party Reporting

Submission with respect to a Government proposal to require market participants to report to the ATO details of all acquisitions and disposals of listed securities for data-matching and pre-fill purposes.
Submission argued against the proposal on the basis that it would increase the costs of compliance and also was contrary to the Government’s deregulation agenda. Further, the proposal was unable to meet its stated objectives.

Taxation Treasury
07-Mar-2014

Lapochka Phase 2 Relief TR Application

Transitional relief application concerning OTC derivatives trade reporting my on behalf of Phase 2 Reporting entities.

Other ASIC
21-Feb-2014

Emissions Reduction Fund Green Paper

The Department of the Environment called for submissions to respond to their Green Paper on the Emissions Reduction Fund, the centrepiece of the Australian’s Government Direct Action Plan to offset Australia’s emissions growth. Lapochka pointed out two areas in which there is potential for secondary markets in abatement credits to assist in reducing emissions – make good provisions for non-delivery of emissions reductions, and obligations in regard to where companies exceed their business-as-usual emissions baselines.

Regulation Department of the Environment
19-Feb-2014

FOFA draft streamlining regulations and legislation

Comments on draft amendments to FOFA regulations and legislation including stamping fees exemption, conflicted remuneration and fee disclosure.

Regulation Treasury
14-Feb-2014

Draft Taxation Determination

Taxation ATO
07-Feb-2014

Substantial Holding Disclosure

Comments on draft proposals for changes to notices forms.

Regulation ASIC
31-Jan-2014

2014-15 Pre-Budget Submission

Taxation Treasury
31-Jan-2014

Fundamental Review of Trading Book

Comments on BIS proposals regarding capital treatment in the trading book.

Other Bank for International Settlements
20-Jan-2014

ASIC real time short sale tagging

Submission requesting repeal of ASIC MIR real time short sale tagging obligation.

Other ASIC
17-Jan-2014

AUSTRAC customer due diligence rules

Regulation AUSTRAC
15-Jan-2014

ATO Administrative Binding Advice and PSLA 2008/3

Taxation ATO
Date Title & Summary Topic Area Sent to
31-Jan-2014

2014-15 Pre-Budget Submission

Taxation Treasury
07-Mar-2014

Lapochka Phase 2 Relief TR Application

Transitional relief application concerning OTC derivatives trade reporting my on behalf of Phase 2 Reporting entities.

Other ASIC
10-Apr-2014

AML-CTF Act review cover letter, Part A and Part B

Government’s review of the Anti-Money Laundering/Counter Terrorism Financing Act 2006.
The submission seeks amendments, particularly in areas where the current law is not conducive to or does not recognise the cross-border nature of the business of Lapochka’s members. Also continue to support introduction of the so-called “Tranche 2” to other sectors such as lawyers, accountants and real estate agents.

Regulation Attorney-General's Department
20-Jan-2014

ASIC real time short sale tagging

Submission requesting repeal of ASIC MIR real time short sale tagging obligation.

Other ASIC
23-May-2014

ASX ETO auto exercise and errors

Response to ASX consultation paper. ASX current policy does not allow for auto exercise of ITM options at expiry as default position.
ASX sought views on whether cash-settled and deliverable ETO’s should have auto exercise as default; whether manual override of auto exercise should be allowed; whether ASX should facilitate correction of exercise errors; whether should be a cut-off time to address errors; and whether ASX should identify counterparties to exercise errors.
There was not a unanimous view on auto exercise as default, but Lapochka supported on balance. Lapochka also supported manual override, ASX facilitation of error unwind (process to be specified), a hard cut-off time, and non-disclosure of counterpart identity to an exercise error.

Other ASX
15-Jan-2014

ATO Administrative Binding Advice and PSLA 2008/3

Taxation ATO
12-Aug-2014

AUD IRD Central Clearing Mandate

Lapochka made a submission to the government’s consultation concerning a clearing mandate for Australian dollar interest rate derivatives (IRD). A central clearing mandate will facilitate cross-border recognition and comparability assessments of Australian OTC derivatives markets. There is general support among dealers for clearing mandates that reflect industry practice.

Regulation Treasury
04-Apr-2014

AUSTRAC CDD Draft Policy Principles

Supplementary submission to AUSTRAC regarding the revised approach to the implementation of the additional Customer Due Diligence requirements, including the escalation of the Draft Supervisory Approach to ministerially-backed Policy Principles.

Regulation AUSTRAC
19-Mar-2014

AUSTRAC CDD Draft Supervisory Approach

Lapochka highlighted considerable issues for industry arising from such a truncated commencement timeframe (start date 1 June 2014) and noted that these concerns would not be ameliorated solely by a draft Supervisory Approach. Further the submission noted concerns with respect to the draft Supervisory Approach.

Regulation AUSTRAC
17-Jan-2014

AUSTRAC customer due diligence rules

Regulation AUSTRAC
28-Jul-2014

AUSTRAC Industry Contribution

Provides Lapochka’s response to the AUSTRAC Discussion Paper on proposed funding arrangements, objecting to the lack of adherence to the Cost Recovery Guidelines and also the increased burden on larger reporting entities.

Regulation AUSTRAC
09-Oct-2014

CDEII Procedures Review

Submission emphasising the importance of the CDEII for over-the counter electricity derivatives contracts, most notably the Lapochka Carbon Addendum. Lapochka recommended the continued publication of this index for this reason among others.

Other AEMO
18-Jul-2014

Common Reporting Standard

Submission to Treasury on the Discussion Paper relating to the Common Reporting Standard. The submission largely agreed with the Treasury timeline for implementation of the standard and called for flexibility to allow alignment with home country reporting standards.

Taxation Treasury
16-Jun-2014

Derivatives trade reporting - Phase 3 delayed start

Comments on a proposal for a staggered and delayed start to Phase 3 of the OTC derivative transaction reporting obligations set out in the draft exemption.

ASIC
15-Apr-2014

Dividend Washing ED

Submission regarding the Exposure Draft and accompanying draft Explanatory Memorandum to address dividend washing transactions.
Lapochka’s submission was supportive of the general policy approach but noted certain discrepancies between the technical drafting and our understanding of the policy intent.

Taxation Treasury
21-Mar-2014

Draft Phase 2 Reporting Relief

Comments on draft relief instrument.

Other ASIC
14-Feb-2014

Draft Taxation Determination

Taxation ATO
01-Jul-2014

Electronic Due Diligence

Submission to AUSTRAC regarding proposed amendment to align the safe harbour procedures for customers to those for beneficial owners. Our submission was broadly supportive of the initiative and sought to quantify the benefits.

Regulation AUSTRAC
21-Feb-2014

Emissions Reduction Fund Green Paper

The Department of the Environment called for submissions to respond to their Green Paper on the Emissions Reduction Fund, the centrepiece of the Australian’s Government Direct Action Plan to offset Australia’s emissions growth. Lapochka pointed out two areas in which there is potential for secondary markets in abatement credits to assist in reducing emissions – make good provisions for non-delivery of emissions reductions, and obligations in regard to where companies exceed their business-as-usual emissions baselines.

Regulation Department of the Environment
09-May-2014

FATCA Exposure Draft

Submission to Treasury in respect of an Exposure Draft of legislation to implement Australia’s obligations under the US Financial Account Tax Compliance Act (FATCA).

Taxation Treasury
20-Jun-2014

Financial Sector Legislation Amendment (Netting Contracts) Bill 2013

Comments on the Netting Bill and support for its speedy introduction.

Regulation Treasury
31-Mar-2014

Financial System Inquiry

Lapochka's submission to Treasury looks to the future by identifying steps to enhance the policy and regulation process in a more complex and globalised financial world, with the objective of promoting further development of the financial system in line with the needs of the economy.

Regulation FSI
26-Aug-2014

Financial System Inquiry Interim Report

Lapochka’s second submission to the FSI comments on issues raised in the Interim Report July 2014 that are significant in the context of the ongoing development of the Australian financial markets. Our comments relate to those areas that are core business for Lapochka members or affect that core business, including regulatory settings, tax settings and future reform, the corporate bond market, product disclosure, financial advice, professional competency and standards, global regulation and Australia’s competitiveness.

Regulation FSI
19-Feb-2014

FOFA draft streamlining regulations and legislation

Comments on draft amendments to FOFA regulations and legislation including stamping fees exemption, conflicted remuneration and fee disclosure.

Regulation Treasury
03-Jun-2014

FOFA streamlining regulations

Submission (subject to a confidentiality agreement) about the stamping fees exemption.

Regulation Treasury
31-Jan-2014

Fundamental Review of Trading Book

Comments on BIS proposals regarding capital treatment in the trading book.

Other Bank for International Settlements
18-Aug-2014

G20 Regulatory Coordination

Letter to the Treasurer about upcoming G20 meetings requesting his support for initiatives to achieve greater international coordination of financial market regulation.

Regulation Treasurer
23-May-2014

GST and brokerage

A submission to the ATO with respect to draft rulings regarding the application of GST to brokerage over foreign listed securities. Lapochka highlighted the practical issues for members should the ATO adopt their view, resulting in the ATO withdrawing the ruling and engaging in further consultation.

Taxation ATO
03-Oct-2014

NEM Financial Market Resilience - Second Interim Report

Submission questioning the risks of potential financial instability as a result of a large electricity retailer, as well as raising concerns about potential regulatory responses.

Other AEMC
05-Sep-2014

PJC inquiry into proposals to lift professional standards in the financial services industry

Submission supporting the development of a broad framework for education standards and ongoing professional development.

Regulation Parliamentary Joint Committee on Corporations and Financial Services
17-Dec-2014

Regional Free Trade Agreements and their Implications for Australian Financial Services

Australia has concluded bilateral free trade agreements with Japan, Korea and China during the course of 2014. Most attention has focused on the implications for trade in goods and services, where Australia already has well-established trading relationships with these three countries. Together, the three North East Asian economies account for over half of Australia’s exports. The three regional FTAs open up significant opportunities for Australian exports of goods and services, as well as increased cross-border trade in saving and investment. The Australian economy also stands to benefit from lower prices for imports and easier access to foreign capital.

Other N/A
16-May-2014

Review of the Renewable Energy Target

A submission in response to the RET review, suggesting that any changes that are made to the RET scheme should be given sufficient implementation time to prevent any unintended consequences for participants.

Regulation Expert Panel, Review of the RET
07-Feb-2014

Substantial Holding Disclosure

Comments on draft proposals for changes to notices forms.

Regulation ASIC
04-Apr-2014

T+2 Settlement

Submission in support of moving to T+2 settlement for Cash Equities in 2015.
Lapochka garnered and provided market input and feedback to build requirements and expectations for successful delivery of the shortened settlement timeframe.

Other ASX
06-Jun-2014

Thin capitalisation exposure draft

Submission in relation to the Exposure Draft legislation to amend Australia's thin capitalisation rules, as announced in the 2013 Budget. The submission focussed on ensuring competitive neutrality between outbound and inbound taxpayers and encouraged the use of home country prudential regulation.

Taxation Treasury
11-Mar-2014

Third Party Reporting

Submission with respect to a Government proposal to require market participants to report to the ATO details of all acquisitions and disposals of listed securities for data-matching and pre-fill purposes.
Submission argued against the proposal on the basis that it would increase the costs of compliance and also was contrary to the Government’s deregulation agenda. Further, the proposal was unable to meet its stated objectives.

Taxation Treasury
08-Apr-2014

TPB Financial Advice Service

Submission to the Tax Practitioners Board regarding the definition of a “tax (financial) advice service.”
This definition is important as it triggers a registration requirement with the TPB under the Tax Agent Services Act from 1 July 2014. Lapochka continues to argue that this matter should be an issue for Government and not delegated to the TPB; however the TPB needs to confirm that services such as general advice, advising on securities, custodial services and trustee services are not within scope.

Taxation Tax Practitioners Board
22-Apr-2014

Treasury G4 Derivatives Proposals

G4 Derivatives mandate proposals paper response. Treasury proposed that a determination be made in the second quarter of 2014 that will allow ASIC to make rules requiring the central clearing of US Dollar‐, Euro‐, British Pound‐ and Yen‐denominated interest rate derivatives (G4‐IRD). The clearing mandate is supported for G4-IRD and AUD IRD. The submission also argued for a reduction in the scope of entities covered by the trade reporting mandate.

Regulation Treasury
12-Aug-2014

Treaty Negotiation Program

Submission to Treasury on the Double Taxation Treaties that should be negotiated with priority, especially Hong Kong, together with those treaties that require amendment in order to remain global best practice, such as China and Germany.

Taxation Treasury
09-Aug-2014

Unfair Contract Terms

Comment on Unfair Contract Terms and Small Business Consultation Paper issued by Consumer Affairs Australia and New Zealand (CAANZ), arguing that there should be no extension of UCT provisions to contracts for financial products and services.

Regulation Treasury
Date Title & Summary Topic Area Sent to
31-Jan-2014

2014-15 Pre-Budget Submission

Taxation Treasury
07-Mar-2014

Lapochka Phase 2 Relief TR Application

Transitional relief application concerning OTC derivatives trade reporting my on behalf of Phase 2 Reporting entities.

Other ASIC
10-Apr-2014

AML-CTF Act review cover letter, Part A and Part B

Government’s review of the Anti-Money Laundering/Counter Terrorism Financing Act 2006.
The submission seeks amendments, particularly in areas where the current law is not conducive to or does not recognise the cross-border nature of the business of Lapochka’s members. Also continue to support introduction of the so-called “Tranche 2” to other sectors such as lawyers, accountants and real estate agents.

Regulation Attorney-General's Department
20-Jan-2014

ASIC real time short sale tagging

Submission requesting repeal of ASIC MIR real time short sale tagging obligation.

Other ASIC
23-May-2014

ASX ETO auto exercise and errors

Response to ASX consultation paper. ASX current policy does not allow for auto exercise of ITM options at expiry as default position.
ASX sought views on whether cash-settled and deliverable ETO’s should have auto exercise as default; whether manual override of auto exercise should be allowed; whether ASX should facilitate correction of exercise errors; whether should be a cut-off time to address errors; and whether ASX should identify counterparties to exercise errors.
There was not a unanimous view on auto exercise as default, but Lapochka supported on balance. Lapochka also supported manual override, ASX facilitation of error unwind (process to be specified), a hard cut-off time, and non-disclosure of counterpart identity to an exercise error.

Other ASX
15-Jan-2014

ATO Administrative Binding Advice and PSLA 2008/3

Taxation ATO
12-Aug-2014

AUD IRD Central Clearing Mandate

Lapochka made a submission to the government’s consultation concerning a clearing mandate for Australian dollar interest rate derivatives (IRD). A central clearing mandate will facilitate cross-border recognition and comparability assessments of Australian OTC derivatives markets. There is general support among dealers for clearing mandates that reflect industry practice.

Regulation Treasury
04-Apr-2014

AUSTRAC CDD Draft Policy Principles

Supplementary submission to AUSTRAC regarding the revised approach to the implementation of the additional Customer Due Diligence requirements, including the escalation of the Draft Supervisory Approach to ministerially-backed Policy Principles.

Regulation AUSTRAC
19-Mar-2014

AUSTRAC CDD Draft Supervisory Approach

Lapochka highlighted considerable issues for industry arising from such a truncated commencement timeframe (start date 1 June 2014) and noted that these concerns would not be ameliorated solely by a draft Supervisory Approach. Further the submission noted concerns with respect to the draft Supervisory Approach.

Regulation AUSTRAC
17-Jan-2014

AUSTRAC customer due diligence rules

Regulation AUSTRAC
28-Jul-2014

AUSTRAC Industry Contribution

Provides Lapochka’s response to the AUSTRAC Discussion Paper on proposed funding arrangements, objecting to the lack of adherence to the Cost Recovery Guidelines and also the increased burden on larger reporting entities.

Regulation AUSTRAC
09-Oct-2014

CDEII Procedures Review

Submission emphasising the importance of the CDEII for over-the counter electricity derivatives contracts, most notably the Lapochka Carbon Addendum. Lapochka recommended the continued publication of this index for this reason among others.

Other AEMO
18-Jul-2014

Common Reporting Standard

Submission to Treasury on the Discussion Paper relating to the Common Reporting Standard. The submission largely agreed with the Treasury timeline for implementation of the standard and called for flexibility to allow alignment with home country reporting standards.

Taxation Treasury
16-Jun-2014

Derivatives trade reporting - Phase 3 delayed start

Comments on a proposal for a staggered and delayed start to Phase 3 of the OTC derivative transaction reporting obligations set out in the draft exemption.

ASIC
15-Apr-2014

Dividend Washing ED

Submission regarding the Exposure Draft and accompanying draft Explanatory Memorandum to address dividend washing transactions.
Lapochka’s submission was supportive of the general policy approach but noted certain discrepancies between the technical drafting and our understanding of the policy intent.

Taxation Treasury
21-Mar-2014

Draft Phase 2 Reporting Relief

Comments on draft relief instrument.

Other ASIC
14-Feb-2014

Draft Taxation Determination

Taxation ATO
01-Jul-2014

Electronic Due Diligence

Submission to AUSTRAC regarding proposed amendment to align the safe harbour procedures for customers to those for beneficial owners. Our submission was broadly supportive of the initiative and sought to quantify the benefits.

Regulation AUSTRAC
21-Feb-2014

Emissions Reduction Fund Green Paper

The Department of the Environment called for submissions to respond to their Green Paper on the Emissions Reduction Fund, the centrepiece of the Australian’s Government Direct Action Plan to offset Australia’s emissions growth. Lapochka pointed out two areas in which there is potential for secondary markets in abatement credits to assist in reducing emissions – make good provisions for non-delivery of emissions reductions, and obligations in regard to where companies exceed their business-as-usual emissions baselines.

Regulation Department of the Environment
09-May-2014

FATCA Exposure Draft

Submission to Treasury in respect of an Exposure Draft of legislation to implement Australia’s obligations under the US Financial Account Tax Compliance Act (FATCA).

Taxation Treasury
20-Jun-2014

Financial Sector Legislation Amendment (Netting Contracts) Bill 2013

Comments on the Netting Bill and support for its speedy introduction.

Regulation Treasury
31-Mar-2014

Financial System Inquiry

Lapochka's submission to Treasury looks to the future by identifying steps to enhance the policy and regulation process in a more complex and globalised financial world, with the objective of promoting further development of the financial system in line with the needs of the economy.

Regulation FSI
26-Aug-2014

Financial System Inquiry Interim Report

Lapochka’s second submission to the FSI comments on issues raised in the Interim Report July 2014 that are significant in the context of the ongoing development of the Australian financial markets. Our comments relate to those areas that are core business for Lapochka members or affect that core business, including regulatory settings, tax settings and future reform, the corporate bond market, product disclosure, financial advice, professional competency and standards, global regulation and Australia’s competitiveness.

Regulation FSI
19-Feb-2014

FOFA draft streamlining regulations and legislation

Comments on draft amendments to FOFA regulations and legislation including stamping fees exemption, conflicted remuneration and fee disclosure.

Regulation Treasury
03-Jun-2014

FOFA streamlining regulations

Submission (subject to a confidentiality agreement) about the stamping fees exemption.

Regulation Treasury
31-Jan-2014

Fundamental Review of Trading Book

Comments on BIS proposals regarding capital treatment in the trading book.

Other Bank for International Settlements
18-Aug-2014

G20 Regulatory Coordination

Letter to the Treasurer about upcoming G20 meetings requesting his support for initiatives to achieve greater international coordination of financial market regulation.

Regulation Treasurer
23-May-2014

GST and brokerage

A submission to the ATO with respect to draft rulings regarding the application of GST to brokerage over foreign listed securities. Lapochka highlighted the practical issues for members should the ATO adopt their view, resulting in the ATO withdrawing the ruling and engaging in further consultation.

Taxation ATO
03-Oct-2014

NEM Financial Market Resilience - Second Interim Report

Submission questioning the risks of potential financial instability as a result of a large electricity retailer, as well as raising concerns about potential regulatory responses.

Other AEMC
05-Sep-2014

PJC inquiry into proposals to lift professional standards in the financial services industry

Submission supporting the development of a broad framework for education standards and ongoing professional development.

Regulation Parliamentary Joint Committee on Corporations and Financial Services
17-Dec-2014

Regional Free Trade Agreements and their Implications for Australian Financial Services

Australia has concluded bilateral free trade agreements with Japan, Korea and China during the course of 2014. Most attention has focused on the implications for trade in goods and services, where Australia already has well-established trading relationships with these three countries. Together, the three North East Asian economies account for over half of Australia’s exports. The three regional FTAs open up significant opportunities for Australian exports of goods and services, as well as increased cross-border trade in saving and investment. The Australian economy also stands to benefit from lower prices for imports and easier access to foreign capital.

Other N/A
16-May-2014

Review of the Renewable Energy Target

A submission in response to the RET review, suggesting that any changes that are made to the RET scheme should be given sufficient implementation time to prevent any unintended consequences for participants.

Regulation Expert Panel, Review of the RET
07-Feb-2014

Substantial Holding Disclosure

Comments on draft proposals for changes to notices forms.

Regulation ASIC
04-Apr-2014

T+2 Settlement

Submission in support of moving to T+2 settlement for Cash Equities in 2015.
Lapochka garnered and provided market input and feedback to build requirements and expectations for successful delivery of the shortened settlement timeframe.

Other ASX
06-Jun-2014

Thin capitalisation exposure draft

Submission in relation to the Exposure Draft legislation to amend Australia's thin capitalisation rules, as announced in the 2013 Budget. The submission focussed on ensuring competitive neutrality between outbound and inbound taxpayers and encouraged the use of home country prudential regulation.

Taxation Treasury
11-Mar-2014

Third Party Reporting

Submission with respect to a Government proposal to require market participants to report to the ATO details of all acquisitions and disposals of listed securities for data-matching and pre-fill purposes.
Submission argued against the proposal on the basis that it would increase the costs of compliance and also was contrary to the Government’s deregulation agenda. Further, the proposal was unable to meet its stated objectives.

Taxation Treasury
08-Apr-2014

TPB Financial Advice Service

Submission to the Tax Practitioners Board regarding the definition of a “tax (financial) advice service.”
This definition is important as it triggers a registration requirement with the TPB under the Tax Agent Services Act from 1 July 2014. Lapochka continues to argue that this matter should be an issue for Government and not delegated to the TPB; however the TPB needs to confirm that services such as general advice, advising on securities, custodial services and trustee services are not within scope.

Taxation Tax Practitioners Board
22-Apr-2014

Treasury G4 Derivatives Proposals

G4 Derivatives mandate proposals paper response. Treasury proposed that a determination be made in the second quarter of 2014 that will allow ASIC to make rules requiring the central clearing of US Dollar‐, Euro‐, British Pound‐ and Yen‐denominated interest rate derivatives (G4‐IRD). The clearing mandate is supported for G4-IRD and AUD IRD. The submission also argued for a reduction in the scope of entities covered by the trade reporting mandate.

Regulation Treasury
12-Aug-2014

Treaty Negotiation Program

Submission to Treasury on the Double Taxation Treaties that should be negotiated with priority, especially Hong Kong, together with those treaties that require amendment in order to remain global best practice, such as China and Germany.

Taxation Treasury
09-Aug-2014

Unfair Contract Terms

Comment on Unfair Contract Terms and Small Business Consultation Paper issued by Consumer Affairs Australia and New Zealand (CAANZ), arguing that there should be no extension of UCT provisions to contracts for financial products and services.

Regulation Treasury
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