Coalition Senators' Dissenting Report

Housing Australia Future Fund Bill 2023 and associated legislation

Background

1.1This legislative package aims to achieve several things. It establishes the $10billion Housing Australia Future Fund (HAFF), the National Housing Supply and Affordability Council and turns the National Housing Finance and Investment Corporation (NHFIC) into ‘Housing Australia’, among other things.

1.2Coalition Senators note that NHFIC was established by the former Coalition Government in 2018 to ‘make loans, investments and grants to improve, directly or indirectly, housing outcomes.’[1] It passed both houses of Parliament on 28 June 2018, and came into effect on 30June 2018.[2]

1.3Before the bill was passed, the draft investment mandate for NHFIC was made public and went through a consultation process from February to March 2018.[3]

1.4There is no proposed investment mandate for the proposed HAFF, the legislation for which is before this Committee.

1.5Coalition Senators believe this is poor practice given the precedent set by NHFIC. If the investment mandate is to be a non-disallowable legislative instrument, then the Parliament and the public should be able to see the investment mandate before the fund corporation bill is voted on.[4]

1.6Coalition Senators note the work of the House of Representatives Standing Committee on Tax Revenue in its inquiry into housing affordability and supply in Australia. On 18 March 2022, the Committee recommended several practical measures that could reduce housing costs. This included encouraging state and local governments to adopt better planning and property administration policies and create higher density areas.[5]

1.7Master Builders Australia have said that government induced costs in housing construction could be reduced ‘through planning and regulatory simplification, better access to land, more level playing field on tax and stability in the economy’.[6]

1.8The House Committee also recommended developing policy allowing for utilisation of superannuation by first home buyers for the purposes of purchasing a home. Yet this bill does not facilitate this. Coalition Senators note that the Government’s proposed ‘objective’ for super, which differs from the objective for super recommended by the David Murray AO in the 2014 Financial System Inquiry, aims to block people from using superannuation for housing.[7]

1.9We believe that allowing people to utilise superannuation for housing is consistent with the purpose of superannuation, which is to provide for better outcomes in retirement. The 2020 Retirement Income Review said that:

The home is the most important component of voluntary savings and is an important factor influencing retirement outcomes.[8]

1.10Stakeholders have recognised that ‘reform of unproductive state planning systems, greater supply of properly zoned brownfields and green fields land’ are desperately needed to make the construction of housing more affordable and easier.[9] The Productivity Commission has recently recommended that ‘State and Territory Governments should revise their planning regulations to ensure residential, commercial and industrial zoning is not unduly restrictive’.[10]

1.11Coalition Senators note that responsibility for such reforms lie with state governments, and the Commonwealth should encourage and incentivize state and local governments to undertake these reforms.

1.12This proposed HAFF will simply funnel off taxpayers’ money, in league with the major super funds, into housing development, with no modelling or guarantee that this will make housing more affordable.

1.13It is a completely warped approach to use taxpayer funds to support super funds buying houses, but not allow people to use their own super to buy their own homes.

1.14Even though no detail about the policy was known, in November 2022, Wayne Swan, the head of the Labor Party and CBUS super fund said: “

And to that end I can outline a CBUS commitment of half a billion dollars over five years to support the HAFF, subject of course to all the necessary commercial settings being workable.[11]

1.15Mr Swan is not the fund’s Chief Investment Officer but has felt he could commit the members’ money to support the Labor Government’s woolly political objective. To date, there is insufficient detail on this policy.

Fuelling Inflation

1.16The Bill appropriates $10 billion in off-budget spending in a time of increasingly higher inflation.

1.17Coalition Senators note that the IMF has said that off-budget spending has an inflationary effect, and that ‘a proliferation of such vehicles should be avoided’.[12]

1.18When asked, the Treasury confirmed on notice that they had not done any modelling on the inflationary impact of the HAFF.[13]

1.19To fight inflation, the Reserve Bank of Australia (RBA) has had to raise interest rates considerably over the last year. As a result, mortgage repayments have increased considerably. For instance, repayments on a $604,000, 30-year mortgage have climbed by 54 percent, according to Moody’s research.[14]

1.20The first thing the Government should do to tackle housing affordability is to help the RBA fight inflation, to mitigate the need for further rate hikes. Adding $10 billion in off-budget spending will exacerbate inflation, not mitigate it, and will increase pressure on monetary policy and interest rates. The Government should be reducing its spending, which will reduce the inflationary impact of fiscal policy.

1.21This must be the Government’s number one economic priority.

Subsiding Big Super

1.22This proposed HAFF represents a questionable partnership between the Albanese Government and the major super funds.

1.23The model of availability payments from the government, via the HAFF, to super funds gives these funds an unfair advantage. During the public hearing, evidence was provided noting that around $100 billion flows into industry super funds annually via compulsory contributions.[15]

1.24The Australian Prudential Regulation Authority (APRA) has confirmed that the amount of compulsory contributions to APRA regulated funds per year has increased by $20 billion over the last 5 years.[16]This is an increase from $93 billion in the Financial Year (FY) 2017–18 to $113 billion in FY 2021-22. Super funds already have a large amount of investable capital. The sector is hugely privileged, charges high fees and depends on a generous government mandate.

1.25Moreover, the super funds already invest heavily into Australian property to the tune of $120 billion according to APRA.

1.26Why the super funds require further incentives in the form of taxpayer funds is unclear. The policy appears to have been developed before the 2022 election by the Australian Labor Party which is chaired by Mr Wayne Swan. Mr Swan also chairs CBUS Super Fund which remains the only super fund committed to the HAFF.

1.27At Budget Estimates on 9 November 2022, the Treasury confirmed that these availability payments would be to ‘support the difference between the returns from the housing project to that required to make it commercially viable’.[17]

1.28It was confirmed that this would essentially constitute payments from the government to the super funds.[18] This would be tax-payer dollars subsidising super fund investments.

1.29At the time, Senator Gallagher could not provide any details on the investment mandate, nor the $350 million in the 2022-23 Budget allocated for availability payments profiled for the five years from 2024-25. She said it was ‘to be resolved’ and that she wasn’t sure about the timetable for future announcements.[19]

1.30On 25 November 2022, even though no detail about the policy was known, Mr Wayne Swan, the President of the Labor Party and Chair of CBUS Super, said:

And to that end I can outline a Cbus commitment of half a billion dollars over five years to support the HAFF.[20]

1.31This was after an investor roundtable in Sydney with Treasurer Jim Chalmers, which Mr Swan attended alongside other super fund Chairs and CEOs.[21]

1.32Mr Swan also said at the time that ‘we believe that investing through the HAFF will meet the best financial interests of our members’.[22] Mr Swan said this when the details of the legislation, let alone the investment mandate at the time, were unknown and not publicly available.

1.33APRA has stated that they expect ‘that an RSE licensee would consider all the Housing Australia Future Fund scheme’s features when considering an investment’, which must be ‘consistent with their obligation to act in the best financial interests of beneficiaries’.[23]

1.34This legislation was only released for public consultation by the Treasury on 19 December 2022, almost a month after the CBUS Chair and ALP President made this funding commitment.[24] At the time of tabling for this Report, details of the investment mandate are still not known.

1.35At the Public Hearing for this legislation, NHFIC said discussions with stakeholders about collaborating with Housing Australia had only been ‘exploratory and preliminary’:

The conversations that we've been having with stakeholders have been very exploratory and preliminary. My overall sense is that there is a high degree of interest from a range of stakeholders in terms of participating in the scheme, but that's obviously subject to seeing the final details in terms of what the HAFF will comprise, particularly the details in the investment mandate.[25]

1.36HESTA, a $70 billion super fund, confirmed that they had not seen the investment mandate, nor have they been approached for consultation.[26]Neither has Industry Super Australia (ISA).[27]

1.37Given all of this evidence, it’s highly curious that a $73 billion super fund such as CBUS would announce such a large commitment to the scheme so early on in the piece.

1.38When asked about the HAFF, APRA providing the following evidence:

APRA expects that an RSE licensee would consider all the Housing Australia Future Fund scheme’s features when considering an investment, including the terms and structure of availability payments and its impact on the investment, including risk and return characteristics.[28]

1.39How could the CBUS Chair, Mr Swan, have considered all the scheme’s features when he made a public $500 million commitment of funding, when no such details had been released?

1.40The Treasury could not provide any information about how much of the appropriated $10 billion will be provided to super funds in availability payments, nor how much would go to foreign fund managers.[29] ISA have said they think it’s likely ‘international pension funds’ would participate in the scheme, which would mean government subsidies could go to foreign entities.[30] Furthermore, Treasury has implied that the model of availability payments was included in advice to the Government when devising the HAFF.

1.41During the public hearing, ISA claimed that without availability payments, such investments in affordable housing ‘would be next to impossible’ from an ‘investment perspective’ in terms ensuring ‘that the investment returns which funds obtain on behalf of members meet their best financial interests’.[31]

1.42ISA noted that historically ‘industry funds have had limited exposure to this particular type of asset, given, by design, it operates at low market rent’.[32] On notice, ISA further stated they think this model would ‘make it more likely that BFID considerations would be satisfied by increasing project cashflows to support an adequate return on capital provided by investors’.[33]

1.43The Government should not be subsidising big super on the basis that certain investments may not satisfy the best financial interests’ duty. The onus is on funds to ensure this.

1.44APRA has confirmed on notice that ‘the proportion of assets managed by APRA regulated super funds in Australian Property is $120.0 billion, representing 5.9% of total investments’.[34] Super funds are already involved in this investment class.

1.45Funds such as Aware Super have been able to invest in housing without such a subsidy mechanism.[35] It begs the question whether such a funding model is really necessary, or if it was part of a hidden agreement between Labor and Big Super in order to funnel taxpayer funds into the sector.

1.46ISA has said that ‘equity ownership’ of housing by super funds may end up being a feature of the HAFF financing model. This would mean taxpayer money, via the HAFF, would be used to subsidise the equity interests of super funds in housing through availability payments.

1.47It would be an absurd situation, if superannuation funds could construct and own a house, with the help of taxpayer dollars, and then rent it out to you, but any notion of allowing people to use their super to buy a house would be excluded under Labor’s proposed objective for super.

1.48If super funds are going to be handed taxpayer funds in order to invest in housing, using members’ savings, then individual members should be given the option to use their own savings to purchase a home. As the Retirement Income Review noted, owning your own home is a significant factor in ensuring better outcomes in retirement.

Investment Mandate

1.49The HAFF Bill 2023 sets out how the Executive Government may issue an investment mandate for the HAFF. This would be a non-disallowable legislative instrument.

1.50The Explanatory Memorandum (EM) justifies this by saying:

The HAFF Bill would provide adequate scrutiny of directions comprising the HAFF Investment Mandate through mandated consultation with the Future Fund Board (clause 44).[36]

1.51Consultation with the Future Fund Board is not an adequate replacement for Parliamentary scrutiny. The Senate Standing Committee for the Scrutiny of Bills has not considered the ‘desire for certainty’ a sufficient justification for making an investment mandate non-disallowable. That Committee said the EM has not ‘adequately explained why the need for certainty is of such an exceptional nature as to justify removing democratic oversight over a law of the Commonwealth’.[37]

1.52The fact that this instrument is non-disallowable is particularly concerning given the Treasury has not released the investment mandate.

1.53Stakeholders have yet to see any details on the investment mandate, and could not answer with certainty how effective the HAFF would be in achieving its objectives without seeing it.[38] Neither the UDIA, Master Builders Australia, PoweringHousing Australia, AHURI nor the Property Council have seen a draft investment mandate.[39] PowerHousing Australia have said that without seeing this investment mandate, it ‘makes it difficult to accurately understand the legislation, as many of its directions given to the Future Fund are not yet known’.[40] The Urban Development Institute of Australia (UDIA) said that the investment mandate will be the ’crux of this’ in terms of how the HAFF would work:

We've heard evidence from numerous people who have been asked: 'What's the capacity? How's it going to work? Will it work?' and everyone comes back to the investment mandate.[41]

1.54The UDIA has further noted that ‘a draft indicative investment mandate would aid understanding of the HAFF bill’.[42] When asked, Master Builders Australia said that it would’ve been better if the draft investment mandate had been released for consultation at the same time as the legislation.[43]

1.55Stakeholders have called for a consultation on this, which seems unlikely to occur until after this legislation has passed. The Future Fund, which the HAFF will be required to consult with under the legislation, have said they have yet to see the investment mandate for the HAFF.[44]

1.56When asked why the investment mandate had yet to be released, the Department of Finance said that it was because it would be subject to legislation that has yet to pass.[45] This argument ignores the precedent set by NHFIC, the investment mandate of which was released months before the structural legislation was passed.

1.57The Treasury could not say whether even a draft of the investment mandate exists.[46] The HAFF investment mandate will be developed by the Department of Finance, whereas the Treasury will develop the investment mandate for Housing Australia (previously NHFIC).[47]

1.58We don’t know whether there will even be a consultation on the investment mandate. We don’t know when it will be released, and whether it will be released before or after the bills currently before the committee are put to the Senate for a vote.

1.59If the investment mandate and future appropriations are non-disallowable, then the only time Parliament will have a say is at the time when the primary legislation is put to a vote.

1.60The Coalition Government carried out a consultation on the investment mandate for NHFIC in February and March of 2018. This was before the enabling legislation was passed by the Parliament at the end of June 2018. It is quite unusual that the Labor Government would seek to pass legislation establishing a new fund, and change the name of the established NHFIC, before undertaking such a consultation.

1.61Coalition Senators note that PowerHousing Australia has said that ‘it would be beneficial for all stakeholders to have the opportunity to review the Investment Mandate before the bill is voted on’.[48]The Government should be transparent about how this fund will work.

1.62The investment mandate will be the key element of the fund.

1.63The HAFF Bill currently before this Committee is simply a shell bill that sets up the structure and architecture of the future fund but provides no detail on how the appropriated funding will be allocated.

Conclusion

1.64Firstly, the HAFF is another example of Labor adding to government spending in a time of inflation. Housing costs, like all costs, are under pressure as a result of the cost-of-living crisis and rising interest rates under the Albanese Government. The Government is not seeking to help the RBA fight inflation by reducing fiscal expenditure, which should be the number one economic priority.

1.65Secondly, the investment mandate for this fund has not been released for consultation, and numerous stakeholders have yet to see any details for it. Several stakeholders have indicated that it should have been released for consultation alongside the primary legislation. This process contradicts the transparent process undertaken by the former Coalition Government during the development of NHFIC in 2018, when the investment mandate was released prior to the Bill passing both houses of Parliament.

1.66As the investment mandate will be non-disallowable, it is disappointing that the government has not indicated that it will release it for consultation prior to the primary legislation being put to a vote.

1.67Finally, the proposal is another example of the Labor working for the superannuation funds rather than individual members. The idea of providing superannuation funds with tax-payer funds in order to subsidise investments in housing, is a bizarre idea that lacks any detail. We don’t know how it will work, and how much money will go to the super funds. It will also create the absurd situation where funds will be able to have an underlying interest in housing, through members’ savings subsidised by the taxpayer, but members will be unable to use their super to buy a home.

1.68Furthermore, it is highly suspect that CBUS Super, prior to any details of the scheme being publically released, would make such a huge commitment to the scheme. Given the CBUS Chair, Mr Wayne Swan, is also national president of the Labor Party, there may be a significant conflict here. The closeness between Labor and Big Super could mean details of the HAFF were provided in advance of any public consultation. The process has been severely lacking in transparency.

1.69The proposed model, which the Parliament has yet to see in detail, would give an enormous advantage to a sector that already receives over $113 billion in mandatory employer contributions per year.[49] Coalition Senators believe that taxpayers should not be providing payments to the superannuation sector to subsidise investments in housing, especially if funds are unable to satisfy the best financial interest duty without these payments. Super funds are already invested in this class of investment without subsidies.

1.70In response to questions on notice, the Property Council noted that ‘30-40% of the cost of each new house and apartment is made up by Federal, State and Local government taxes and charges’.[50] Coalition Senators think that measures should be taken to reduce the regulatory costs on planning and housing construction, and the Commonwealth should incentivise state and local governments to undertake such reforms.

1.71Coalition Senators believe that instead of subsidising superannuation fund investment in housing, the Government should allow members’ to use their super to buy a home.

1.72The Housing Australia Future Fund Bill 2023 should not pass.

1.73The consequential amendments for the HAFF in Schedule 4 of the Treasury Laws Amendment (Housing Measures No. 1) Bill 2023 should not pass.

Senator Dean Smith

Member

Senator for Western Australia

Footnotes

[1]Parliament of Australia, National Housing Finance and Investment Corporation Act 2018: a quick guide, National Housing Finance and Investment Corporation Act 2018: a quick guide – Parliament of Australia (aph.gov.au) (accessed 22 March 2023).

[2]Parliament of Australia, National Housing Finance and Investment Corporation Bill 2018, National Housing Finance and Investment Corporation Bill 2018 – Parliament of Australia (aph.gov.au) (accessed 22 March 2023).

[3]Department of the Treasury (Treasury), National Housing Finance and Investment Corporation—draft Investment Mandate, National Housing Finance and Investment Corporation – draft Investment Mandate | Treasury.gov.au (accessed 22 March 2023).

[4]Revised Explanatory Memorandum, p. 30.

[5]House of Representatives Standing Committee on Tax and Revenue, Inquiry into Housing Affordability and Supply in Australia, ‘List of Recommendations’, https://www.aph.gov.au/Parliamentary_Business/Committees/House/Former_Committees/Tax_and_Revenue/Housingaffordability/Report/section?id=committees%2freportrep%2f024864%2f78747 (accessed 23 March 2023).

[6]Master Builders Australia (MBA), Response to questions on notice from Senator Bragg received 17March 2023, p. 2.

[7]Treasury, Legislating the objective of superannuation, ‘Consultation Paper’, March 2023, Legislating the objective of superannuatio https://treasury.gov.au/consultation/c2023-361383n | Treasury.gov.au (accessed 22 March 2023).

[8]Treasury, Retirement Income Review—Final Report, July 2023, https://treasury.gov.au/sites/default/files/2021-02/p2020-100554-udcomplete-report.pdf (accessed 22 March 2023).

[9]Property Council of Australia, Submission 7, p. 1.

[10]Productivity Commission, Recommendation 3.2, 5-year Productivity Inquiry: Advancing Prosperity, Vol 1, p. 93.

[11]The Australian, Cbus commits 500m to help tackle diabolical housing affordability issues, 26November 2022,https://www.theaustralian.com.au/nation/cbus-commits-500m-to-help-tackle-diabolical-housing-affordability-issues/news-story/4edded5806eaf465a87ad821648d471d (accessed 22 March 2023).

[12]John Kehoe, Financial Review, ‘Off budget’ spending adds to inflation pressure, Off budget’ spending adds inflation pressure”: Rewiring the Nation, National Reconstruction Fund, Housing Australia Future Fund (afr.com) (accessed 22 March 2023).

[13]Treasury, Treasury IQ23-000033—Responses to questions on notice from Senator Bragg received 17 March 2023, p. 2.

[14]Shane Wright, The Sydney Morning Herald, Housing affordability crumbles as mortgage repayments hit record level, March 8 2023, Interest rates: Housing affordability crumbles as mortgage repayments hit record level (smh.com.au) (accessed 23 March 2023).

[15]Mr Matthew Linden, Deputy Chief Executive, Industry Super Australia, Committee Hansard, 15 March 2023, p. 44.

[16]Australian Prudential Regulatory Authority (APRA), APRA01QoN - Responses to questions on notice from Senator Bragg received 20 March 2023, p. 2.

[17]Ms Diane Brown, Deputy Secretary, Revenue, Small Business and Housing Group, Treasury, Committee Hansard, 9 November 2022, p.14.

[18]Ms Diane Brown, Deputy Secretary, Revenue, Small Business and Housing Group, Treasury, Committee Hansard, 9 November 2022, p.14.

[19]Senator Katy Gallagher, Minister for Finance, Committee Hansard, 9 November 2022, p.31.

[20]The Australian, Cbus commits 500m to help tackle diabolical housing affordability issues, 26 November 2022, https://www.theaustralian.com.au/nation/cbus-commits-500m-to-help-tackle-diabolical-housing-affordability-issues/news-story/4edded5806eaf465a87ad821648d471d (accessed 22 March 2023).

[21]The Hon Dr Jim Chalmers MP, Treasurer, Treasurer’s Investor Roundtable—Media Release, 7October2022, https://ministers.treasury.gov.au/ministers/jim-chalmers-2022/media-releases/treasurers-investor-roundtable (accessed 22 March 2023).

[22]The Australian, Cbus commits 500m to help tackle diabolical housing affordability issues, 26 November 2022, https://www.theaustralian.com.au/nation/cbus-commits-500m-to-help-tackle-diabolical-housing-affordability-issues/news-story/4edded5806eaf465a87ad821648d471d (accessed 22 March 2023).

[23]APRA, APRA01QoN - Responses to questions on notice from Senator Bragg, 15 March 2023 (received 20 March 2023), p. 1.

[24]Treasury, Housing Legislative Package—Housing Australia Future Fund Bill, National Housing Supply and Affordability Council Bill, and Amendment Bill—Exposure Draft Consultation, January 2023, https://treasury.gov.au/consultation/c2022-343652 (accessed 22 March 2023).

[25]Mr Nathan Dal Bon, Chief Executive Officer, National Housing Investment and Finance Corporation, Committee Hansard, 15 March 2023, p. 67.

[26]HESTA—Response to questions on notice from Senator Bragg, 15 March 2023, (received 17March2023), p. 3.

[27]Industry Super Australia, Response to Senator Andrew Bragg's questions on notice, 15 March 2023 (received 20 March 2023), p. 3.

[28]APRA, APRA01QoN - Responses to questions on notice from Senator Andrew Bragg, 15March2023, (received 20 March 2023), p. 1.

[29]Department of the Treasury IQ23-000034—Responses to questions on notice from SenatorAndrewBragg, 15 March 2023, (received 17 March 2023), p. 1.

[30]Mr Matthew Linden, Deputy Chief Executive, Industry Super Australia, Committee Hansard, 15March 2023, p. 44.

[31]Mr Matthew Linden, Deputy Chief Executive, Industry Super Australia, Committee Hansard, 15March 2023, p. 44.

[32]Mr Matthew Linden, Deputy Chief Executive, Industry Super Australia, Committee Hansard, 15March 2023, p. 40.

[33]Industry Super Australia, Response to Senator Andrew Bragg's questions on notice, 15 March 2023 (received 20 March 2023), p. 2.

[34]APRA, APRA01QoN - Responses to questions on notice from Senator Bragg received 20March2023, p. 2.

[35]Michael Bleby, Financial Review, Aware Super backs $300 million affordable housing project, 9 February 2021, https://www.afr.com/property/commercial/aware-super-backs-300-million-affordable-housing-project-20210209-p570up (accessed 22 March 2023).

[36]Revised Explanatory Memorandum, p. 30.

[37]Senate Standing Committee for the Scrutiny of Bills, Scrutiny Digest 2/23, 8 March 2023 p. 7.

[38]Mr Nicholas Proud, Chief Executive Officer, PowerHousing Australia, Committee Hansard, 15 March 2023, pp. 11 - 12.

[39]Urban Development Institute of Australia (UDIA)—Responses to questions on notice from Senator Bragg, 15 March 2023 (received 17 March 2023), p. 3; Master Builders Australia (MBA)—Response to questions on notice from Senator Andrew Bragg, 15 March 2023 (received 17 March 2023), p. 1; PowerHousing Australia—Responses to questions on notice from Senator Andrew Bragg, 15March2023, (received 17 March 2023), p. 3; Australian Housing and Urban Research Institute (AHURI)—Responses to questions on notice from Senator Andrew Bragg, 15 March 2023, (received 16 March 2023), p. 2; Property Council of Australia—Responses to questions on notice from SenatorAndrew Bragg, 15 March 2023, (received 21 March 2023), p. 2.

[40]PowerHousing Australia, Submission 6, p. 5.

[41]Mr Andrew Minho, Head, Policy and Government Relations, Urban Development Institute of Australia (National), Committee Hansard, 15 March 2023, p. 36.

[42]Urban Development Institute of Australia (UDIA)—Responses to questions on notice from SenatorAndrew Bragg, 15 March 2023, (received 17 March 2023), p. 2.

[43]Master Builders Australia (MBA)—Response to questions on notice from Senator Andrew Bragg, 15 March 2023, (received 17 March 2023), p. 1

[44]Mr Cameron Price, General Counsel and Chief Risk Officer, Future Fund Management Agency, Committee Hansard, 15 March 2023, p. 64.

[45]Mr Scott Dilley, First Assistant Secretary, Department of Finance, Committee Hansard, 15 March 2023 p. 64.

[46]Mr Robert Raether, First Assistant Secretary, Housing Division, Treasury, Committee Hansard, 15March 2023, p. 65

[47]Treasury IQ23-000033—Responses to questions on notice from Senator Andrew Bragg, 15March2013, (received 17 March 2023), p. 2.

[48]PowerHousing Australia—Responses to questions on notice from Senator Andrew Bragg, 15March2023, (received 17 March 2023), p. 3

[49]APRA, APRA01QoN - Responses to questions on notice from Senator Andrew Bragg, 15March2023, (received 20 March 2023), p. 2.

[50]Property Council of Australia—Responses to questions on notice from Senator Andrew Bragg, 15March 2023, (received 21 March 2023), p. 1.