ISA welcomes the recognition by the Royal Commission and APRA that how remuneration
systems operate within financial entities has important implications for how those entities
behave and treat their customers and members. We therefore welcome consultation on APRA’s
proposed reforms to the prudential regulation of remuneration design and implementation.
In this submission we comment on a number of issues raised by the draft of CPS 511 and APRA’s
Discussion Paper. We argue that several important matters remain unclear and unresolved. ISA
would therefore welcome further opportunities to engage with APRA on these matters before a
final CPS 511 is issued.
In addition to the matters discussed below, ISA notes that APRA intends to consult at a later
date on introducing enhanced disclosure requirements relating to the publication of each
entity’s remuneration policy and the use of specific performance metrics. ISA supports
enhanced disclosure and looks forward to engaging with the consultation when it takes place.