The Australian Bankers Association turned to industry data, rather than ABS data, in making its case on margins in its submission to the Senate banking inquiry.Using NAB data, the ABA said that prior to August 2007 the cost above the 90-day overnight index swap was a spread of "only about 8-10 basis points". "The spread during August 2010 has averaged 24 basis points or about three times higher than pre-GFC levels."For long-term funding, the ABA used CBA data."Pricing for banks long-term issuance remains about 100 basis points above swap (at August 2010) for three-year terms," the ABA wrote."These spreads are about eight times higher than pre-GFC levels. "Prior to the GFC, banks could raise three-year term funding at around 12 to 15 basis points above the benchmark rate. "Spreads averaged as high as 242 basis points in March 2009."