Submissions

  • Competition in the Financial System

    Posted: 29 March 2018

    Industry superannuation funds act as custodians of the retirement benefits of millions of Australians. They are run only to benefit members, and therefore place a heavy priority on the long-term financial interests of our members as employees, retirees and citizens within a growing productive economy. This ‘member-first’ approach implies a particular understanding of the role that our financial sy...

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  • Means Test Rules for Lifetime Retirement Income Streams

    Posted: 16 February 2018

    Industry superannuation funds look after the retirement savings of over half the working population. Industry Super Australia’s mission is to maximise the retirement incomes of industry super fund members, and to advocate for public policy and superannuation industry practice consistent with this goal.

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  • Treasury Laws Amendment (Taxation and Superannuation Guarantee Integrity Measures) Bill 2018

    Posted: 16 February 2018

    There are welcome initiatives in the Exposure Draft for this Bill. However, when you look at the detail of this proposed legislation, the broad claims made about the package look thin, particularly in the area of making underpayment more identifiable.

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  • Establishment of the Australian Financial Complaints Authority

    Posted: November 2017

    Superficially the combining of three different financial services complaints bodies into a new ‘one stop shop’ appears to have efficiency benefits. However, a deeper examination reveals profound challenges, which will be difficult for AFCA to overcome.

    These challenges include: concerns that superannuation fund complainants will not be better off; that trustees may face conflicting duties under...

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  • ASIC Enforcement Review: Consultation Paper on ASIC’s Directions Powers

    Posted: 23 November 2017

    Observing ASIC’s regulatory outcomes since the Global Financial Crisis it is clear that there are regulatory and enforcement tools missing from ASIC’s regulatory tool box.

    Limitations in ASIC’s regulatory suite were first highlighted by the CBA and Macquarie Bank Enforceable Undertakings (EU). More recently we have seen issues in the regulation of data collection in life insurance, supervision...

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