The Council of Financial Regulators needs to "play a more active and transparent role in assessing the economy-wide impacts of new or changed regulation and coordinating the activities of different regulators," the Australian Bankers Association said in its submission to the Financial System Inquiry. Giving emphasis to one long-standing industry beef, the ABA said that "given the strength of our existing regulatory regime, we should be sceptical of the need for ever more regulation. "Instead, what the industry has experienced over the past five years has been a wave of regulatory change, driven by international rule making, the extraterritorial impacts of US legislation and a range of, at times ad hoc, regulatory interventions from Government responding to domestic issues."The current Government's commitment to a moratorium on significant new financial regulation is therefore a welcome pause for the industry. "One of the challenges Australia faces is that, increasingly, the rules for financial systems are determined outside of Australia's borders. This trend reflects the growing globalisation of the financial system and was apparent before the Global Financial Crisis. That crisis, however, has rapidly accelerated the trend. "As a consequence, large parts of the Australian regulatory regime are determined in international negotiations and are often shaped to deal with problems not experienced in Australia. "Australia has little choice but to accede to these international rules. "While Australian negotiators have often been able to influence these rules to recognise unique Australian circumstances, Australia is left with a dilemma: the major rules that shape the banking system are not determined with Australia's circumstances in mind. "It is critical therefore that Australian regulators use, to the full extent possible, any national discretions within international rule-making to ensure the rules applied within Australia meet our own needs, while satisfying international requirements. "There need to be good reasons, for example, for accelerating the adoption of international rules in Australia, especially if these rules are designed to address problems not experienced here."