Submissions

  • Superannuation inquiry - supplementary submission regarding performance research

    Posted: 5 April 2018

    This paper addresses the claims by some, particularly representatives of retail superannuation funds, that performance comparisons of superannuation funds based on fund-level performance are not appropriate or relevant.

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  • Effectively assessing member outcomes

    Posted: 29 March 2018

    The proposed SPS 225 will require an RSE licensee to annually assess all member outcomes. At a minimum it requires the RSE licensee to detail how it has designed its assessment including how it has decided to segment its business, the metrics it has used to measure beneficiaries outcomes and its conclusions as to whether the outcomes it seeks to provide are being met.

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  • Summary comments on Treasury Laws Amendment (Design and Distribution Obligations and Product Intervention Powers)

    Posted: 12 February 2018

    The design and distribution obligations have been conceived of to address shortcomings in the ability of disclosure to protect consumers. To this end, a key objective of the amendments is to ensure that product issuers consider and define their intended target market and how they distribute to consumers in that target market.

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  • RG97 Review

    Posted: 6 February 2018

    RG97 could have been a more effective document if it considered more carefully the way consumers interact with disclosure and indeed the realities of superannuation.

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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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