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Banking Executive Accountability Regime (BEAR): KPMG’s submission to Treasury

Banking Executive Accountability Regime submission

The Australian Government is seeking to better define the accountabilities of key financial services executives and introduce consequences such as civil penalties and remuneration constraints in an attempt to better align rewards with long-term performance, discourage inappropriate risk-taking amongst banking executives and respond to growing community concerns that financial institutions have a ‘poor compliance culture’.


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On 3 August 2017 KPMG submitted a response to Treasury on their Consultation Paper.

The views expressed in our submission reflect KPMG's understanding of the key issues which need to be considered by Treasury and APRA based on the unique dynamics of the Australian financial services environment, our international experience and our understanding of the interests of market participants.

We have focused on responding to those areas of the paper where we had a distinctive point of view, including:

  • the institutions to be covered by the BEAR
  • the individuals to be covered by the BEAR
  • expectations of ADIs and accountable persons under the BEAR
  • BEAR impacts on foreign institutions
  • BEAR impact on remuneration
  • implementation and transitional issues.

We believe the proposed BEAR provides an opportunity to further embed governance standards and enhance corporate culture to drive stronger long-term performance for shareholders and ensure more accountability to broader stakeholders.

Read our submission.

© 2020 KPMG, an Australian partnership and a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative ("KPMG International"), a Swiss entity. All rights reserved. Liability limited by a scheme approved under Professional Standards Legislation.

KPMG International Cooperative (“KPMG International”) is a Swiss entity. Member firms of the KPMG network of independent firms are affiliated with KPMG International. KPMG International provides no client services. No member firm has any authority to obligate or bind KPMG International or any other member firm vis-à-vis third parties, nor does KPMG International have any such authority to obligate or bind any member firm.

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