National Australia Bank has warned that the Federal Government's new effort to make bank executives more accountable to shareholders and customers could result in a "detrimental" shift in financial services regulation and undermine APRA's relationships with banks.In a definitively negative and perhaps over-pitched submission to the Treasury consultation on the proposed Banking Executive Accountability Regime, the country's fourth-largest bank exhorted the Turnbull government to rethink proposals to give more powers to APRA."The BEAR has the potential to materially change the role of APRA as prudential regulator, and in doing so undermine its supervisory relationship with ADIs," NAB said."The exercise by APRA of its enhanced powers based on the proposed new expectations under the BEAR could result in a fundamental and detrimental shift in regulation of the financial services industry in Australia."It could also mark a departure from Australian legal jurisprudence."Under changes outlined by Treasury in July, APRA will have stronger powers to remove directors and senior executives from regulated deposit-taking institutions if they fail to conduct their businesses with integrity and meet expectations of "due skill, care and diligence".The reforms will give APRA more scope to intervene in the operations of banks and their subsidiaries after it forms a view that there has been poor conduct or behaviour of a "systemic and prudential nature".According to the proposals, APRA will have authority to remove senior executives, board members and even the managers of subsidiaries such as financial advice arms if systemic poor conduct is identified.APRA will also have some discretion in determining which management staff outside of a bank's senior executive team are deemed to be "accountable persons" under the new regime.Such a widening of APRA's role appears to have spooked executives and board members at NAB more profoundly than their counterparts at two of its major rivals - ANZ and Westpac."Whilst NAB recognises the rationale for providing APRA with enhanced powers in certain circumstances, NAB believes that APRA should not be permitted to disqualify someone without a fair and clearly defined process, including judicial determination of breach, in line with the current requirement for APRA to apply to the Federal Court," the bank told Treasury."It is unnecessary for the BEAR to introduce a new definition of 'accountable persons' since the existing prudential standards provide a workable, effective and well understood definition of the most senior and influential executives in an ADI."NAB is opposed - unequivocally - to the prospect of a broader definition of "accountable persons" which would include board chairs and non-executive directors who oversee the work of risk and audit committees."NAB does not consider it appropriate to include non-executive directors in chair roles as accountable persons," the bank said in its submission."This does not reflect governance practice/board structures or the operation of board committees, and creates 'classes' of directors."The defensive, almost aggressive, tone of NAB's submission is a marked contrast to the Westpac response to the Treasury white paper.In its submission, Westpac stated that: "Overall, we believe that the implementation of the Regime, working alongside Australia's broad governance