As the IDR process is an extremely important part of the consumer protection framework it is imperative that any changes made to RG 165 deliver a better experience for members. For this reason, ISA agrees with most of the changes proposed to the IDR framework. However, there are unique considerations in the superannuation sector that have not been considered in the proposed changes that need to be addressed for the changes to be effective. For example, issues arise regarding the respective reporting roles and timeframes of trustees, administrators and insurers. These are discussed in the body of this submission.
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