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Submission on draft Prudential Practice Guide SPG 516 – Business Performance Review image
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Submission on draft Prudential Practice Guide SPG 516 – Business Performance Review

Published: 10 Oct 2019

ISA welcomes the focus on member outcomes by government contained in recent legislative amendments1. It is long
overdue and has potential to protect and advance the interests of superannuation fund members.

Superannuation trustees are waiting for the making of regulations set out in s 52(9) of the Superannuation Industry
(Supervision) act 1993 (SIS Act) which will support the member outcomes laws and set benchmarks licensees must
use to determine whether the financial interests of members are being promoted. The regulations when made will
provide a standardised and objective framework for trustees to assess the net returns delivered to beneficiaries for
MySuper products, choice products and the fund as a whole.

Unfortunately, APRA’s proposed prudential guidance appears to have been drafted without reference to
standardised performance benchmarks and as a result adopts an overly cautious approach that risks being
ineffectual and clearly fails to realise potential of these laws. In place of robust and consistent measures that will
improve outcomes for millions of members, the proposed guidance takes an approach that invites inconsistent,
divergent and potentially self-serving approaches to performance and outcomes being adopted by some funds.

You can read the full submission below. 

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