There’s no silver bullet to successfully managing PDSs. But there are a number of measures that every fund can put in place to ensure quality documents for members while minimising risk to the fund. Here are six essential steps to help your entire team achieve a successful outcome.
1 – Due Diligence
Firstly, you really must have a formal due diligence (DD) set up. There are still funds signing off PDSs the same way they sign off marketing materials. How this would stand up to scrutiny from ASIC or AFCA I don’t know.
A formal DD means a DD memo that sets out the expectations and processes that are to be followed. Generally one of those expectation is that every sentence in every document (since a ‘PDS’ generally comprises a number of actual documents) is verified, and evidence provided. Plus at least one DD meeting where the DD committee agrees that the PDS being updated is not misleading or deceptive in any way, and is ready to go to market. We see a number of different approaches to DD across the industry, what’s important is that there is a commitment to verification and provision of evidence, plus a clear chain of command for signoff.
2 – Excellent project management
We find that many super funds have just one person who is responsible for project managing their PDS rolls to ensure that the quality is high and the timeline is met. Unfortunately however, the more skilled this person is, the higher the key person risk! When one person holds a huge amount of corporate knowledge and history in their head and inbox, if they leave (or are simply unavailable for whatever reason), then there is a high likelihood that something will slip through the net. How do you overcome this? With technology (but more on that shortly).
3 – Processes and procedures (that are followed without fail)
When the pressure is on, it’s all too easy to cut corners and try to ‘push through’. With PDSs however, this is a high-risk manoeuvre. This is where your expert project manager will come to the fore, as they will ensure that the agreed process and procedures are followed to the letter. As any medical surgeon will tell you, when everything is going wrong, the procedures that have been drilled into everyone are what saves the day.
4 – Clear roles and responsibilities
What goes with processes and procedures? Clear roles and responsibilities. Everyone involved needs to know exactly what they are responsible for – both in terms of which sections of text, and any procedural responsibilities they might have. Most people we meet understand the importance of a quality PDS, but there are still a few laggards who ‘only read the third draft’ or worse, sign verification certificates without properly reviewing the contents. Of course, dear reader, we are talking about other funds here, not yours.
5 – Enough time to do a good job
Sometimes (okay, often when it comes to PDSs) one of the key reasons that your staff shirk their responsibilities (on purpose or otherwise) is that they simply don’t have enough time to do a good job. When PDS reviews are done at 7am or 9pm (which they often are), ‘just getting through it’ becomes the primary driver instead of ‘how can I contribute to making sure this is a quality document’.
At the recent ASFA Spotlight on Insurance event, I asked the participants to raise their hand if they had done a review under these conditions. Every hand in the room went up. And here in lies the rub. It just doesn’t matter how good your DD memo is, your project manager, your roles and responsibilities, your processes and procedures – if your people don’t have enough time to review the documents in a considered manner, then you are NEVER going to get a quality outcome.
6 – Technology
To my mind, this is the ONLY way to deliver all the above, but most importantly, number five. There is simply only so much you can do with MS Word, Excel and Indesign. A good project manager will push the capabilities of these programs to their natural limit (and sometimes beyond), but that still leaves you with key-person risk and a huge number of person-hours to get a decent outcome.
Luckily, there is now quality PDS technology available that can transform your disclosure regime. And there are three main components that you should be looking for:
- mail merge on steroids (because as we all know, the same text is often used in multiple documents so you only want to be reviewing it once)
- publishing from within the system (to remove risk of transposition errors between Word and Indesign, to say nothing of the time this part of the process takes)
- verification capability (so that each piece of text has a clear owner, and supporting evidence is stored alongside the words).
It’s not only about the software though. The other issue around technology is to remember that a huge amount of content is now consumed via phones rather than desktops. Have you tried to read an A4 PDF on a phone? It’s no fun at all. Given the way information is consumed, it’s less than ideal that most PDSs are produced only as PDFs. Quality PDS software should also allow you to publish your PDSs as html, so your members (and potential members) can read up about your fund on their phone. It’s no good saying that we’re all about ‘member engagement’ if we’re not delivering the most fundamental information in a way that can be easily consumed.
What are we really trying to achieve?
Whenever considering how to improve something, it’s always worth coming back to the desired outcome. In this case, it’s for a set of documents that are written in plain English and can be easily understood by a lay person. Not an easy task in an environment as jargon-laden as superannuation. But it IS possible.
And it’s up to all of us, as participants in and stewards of the super system, to do our very best to help members understand what it’s all about, and to make considered decisions about their individual financial futures.