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Analysis:
Analysis
19 Apr 2023
5 minute read

Superannuation transfer planning: Proposed enhancements

Deloitte response to consultation

Consultation response
330 KB PDF

The APRA discussion paper outlines proposed enhancements to the current Prudential Standard SPS 515 Strategic Planning and Member Outcomes (SPS 515) and Prudential Practice Guide SPG 227 Successor Fund Transfers and Wind-ups (SPG 227).

The introduction of the Annual Superannuation Performance Test and the focus on sustainability across the superannuation market has increased inorganic growth activity amongst funds over the past three years. Whilst the response by some funds to such measures has been to tighten their cost models or make changes to their investment strategy to protect performance, a significant number of other registrable superannuation entities (RSE) licensees used this as the trigger to seek a merger with another RSE licensee to transfer members and assets.

We agree with the strong emphasis that has come through in recent prudential standards on reaffirming the focus on member outcomes and given the trend on transfer activity shows no signs of slowing down, aligning the various prudential standards would support the industry further.

Our response focuses on the key themes that we would consider important to consider when making any updates to SPS 515 and SPG 227 to ensure that this supports the industry, whilst avoiding any unintended consequences which could have the opposite effect of enhancing transfer planning and implementation.

 

More about the authors

Andrew Boal

Deloitte - Australia
Andrew is a partner in Deloitte’s Melbourne office in the Actuarial Consulting practice. Andrew has spent more than 30 years advising clients on superannuation, life insurance, employee benefits, risk management, investments and talent management. During his career, Andrew has also driven research and public policy in various areas of interest, including retirement income products and solutions, retirement adequacy, member disclosure and advice, member engagement and digital solutions, governance and managing conflicts.
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Steve Freeborn

Deloitte - Australia
Steve is a partner in Deloitte’s Sydney office in the Actuarial Consulting practice. Steve has over 25 years’ experience in the financial services industry across all parts of the value chain, bringing a high level of market knowledge together with a deep technical knowledge of the superannuation, insurance and investment industries and participants. Steve’s areas of focus include: Member engagement, including tools and calculators to support our member research. Operations/ operational efficiency, including development of target operating models, support around regulatory developments, benchmarking and tenders of and for third-party service providers, and remediation activities. Product and proposition, including strategy development and M&A support, product development and validation, and market entry strategies.
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Melissa Gomes

Deloitte - Australia
Melissa has over 20 years’ experience in governance, risk, compliance and operations in financial services, specialising in superannuation. Melissa has held senior roles within the superannuation industry. She has strong experience working with trustees, specifically in respect of governance, compliance and risk management frameworks, and has led several superannuation-focused regulatory change programs, assisted operational change programs across both trustee businesses and superannuation operations, as well as multiple complex successor fund transfers of complex funds. Melissa provides subject matter expertise for superannuation fund internal audit and assurance reviews and has supported clients in the delivery of responses to APRA licensing conditions, covering risk management, insurance in superannuation, resourcing and outsourcing.
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