Before answering your question, can I ask how much experience you have in regulation? Because you're referring to "minimum capital requirements" and tieing that to lending requirements so I'm not sure what you're going on about.
I've already mentioned that the capital requirements the bank faces are for the purposes of protecting the depositors of the bank. This is completely and unequivocally different to responsible lending practices. So taking this into mind, it may be worth for you to re-read my earlier comment and try and understand it.
APT is NOT an authorized deposit-taking institution and therefore doesn't have depositors to protect, hence they are not bound to capital requirements of banks as per APS 110: Capital Adequacy
https://www.apra.gov.au/sites/defau...l_standard_aps_110_capital_adequacy_clean.pdf
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