ASFA Action, Issue 526, 13 February 2014
ASFA’s submission: Treasury discussion paper on regulation, governance, transparency and competition
ASFA has lodged its submission in response to the Treasury discussion paper Better regulation and governance, enhanced transparency and improved competition in superannuation.
To prepare the submission, ASFA sought the feedback of its members, industry experts, the ASFA Board and Policy Councils. ASFA would like to thank everyone who provided input and worked hard during what has been a long and challenging process.
This submission required an enormous amount of work, not only from the ASFA Policy team, but also many members. We also tested our draft versions with the ASFA Board Policy Committee on a number of occasions, and researched independent data to present policy that is objective and as evidence-based as possible.
At this important time for the super industry, the submission is about showing that ASFA is willing to raise our standards in line with higher expectations in the community and in relation to governance, transparency and competition.
The submission proposes:
- specific areas where regulatory reform could be undertaken to reduce compliance costs
- improvements to the regulatory reform process, including adequate consultation, clear drafting, appropriate requirements, adequate implementation timeframes, regulator guidance and post implementation reviews, which will serve to reduce unnecessary costs
- a definition of ‘independent trustee’ that incorporates the major elements from the current SIS Act definition and ASX guidelines
- flexibility to appoint independent directors, with support for a third of the trustee board being independent
- 9-12 year tenure for directors, independent chairs and a ban on multiple directors (unless circumstances are exceptional)
- deferral of the dashboard for choice products until current concerns with the MySuper dashboard have been addressed, and there has been consultation on the need for, and appropriate design of, the choice dashboard
- a modified portfolio holdings disclosure regime, with partial look through and a materiality threshold. However, we would prefer a more innovative, consumer-friendly approach to disclosure
- suggestions of alternative processes for the Fair Work Commission, to address transparency and cost issues with the current requirements.
The submission is available on the ASFA website.
If you have any questions, please contact ASFA CEO Pauline Vamos.