The paper is in response to recommendation three of the Final Report of the 2014 Financial System Inquiry (FSI).
The paper proposes an increase in Total Capital requirements of between 4% and 5% of risk-weighted assets (RWA) for domestic systemically important banks (D-SIBs), such as ANZ. Based on ANZ’s RWA of $391bn as at 30 September 2018, this represents an incremental increase in the Total Capital requirement of approximately $16 billion to $20 billion, with an equivalent decrease in other senior funding.
APRA anticipates that D-SIBs would satisfy the requirement predominantly with additional Tier 2 capital. D-SIBs will need to satisfy the new requirement by 2023.
ANZ intends to consult with APRA and provide a response.
 Pp 67-75 Final Report of the FSI which recommended that the Government “implement a framework for minimum loss absorbing capacity in line with emerging international practice, sufficient to facilitate the orderly resolution of Australian authorised deposit taking institutions (ADIs) and minimise taxpayer support” .
 D-SIBs have an implementation period of four years from the release of the final Total Capital requirements (expected in 2019)