Administration and Technology

Administration and Technology

AIST’s Administration and Technology Policy Position

Technology and best practice are constantly changing.  AIST strives to ensure that our members provide a service that is valuable and up to date.  We will continue to push for greater personal improvement, and we see continuing professional education as key.

AIST supports innovation and is a key force behind technological change such as SuperStream and the challenges of big data.  We understand that our funds owe our members the best service that they can deliver in the interests of their members.

Select from our range of publications on this topic below: 

 

16 Mar 2016 - Consumer protection for late super payments retained in full

AIST has welcomed the retention of the full Superannuation Guarantee Charge – an important consumer protection measure for superannuation payments to employees – following debate in Parliament earlier today.

13 Nov 2015 - AIST Awards recognise essential role of digital in superannuation

Clever use of data segmentation and social media campaigns to improve female engagement with super for women were recognised at AIST’s 2015 Awards for Excellence last night.

13 Mar 2015 - What will the superannuation industry be like in 2025?

A survey of the superannuation industry by AIST and BNP Paribas Securities Services has shown the world we are planning for today will be very different in 10 years' time.

26 Aug 2014 - Renovate the house don’t pull it down – AIST responds to the Financial System Inquiry

The Australian Institute of Superannuation Trustees (AIST) said today Australia’s $1.85 trillion superannuation system is on track to deliver further cost savings and value to members with the recently launched MySuper having already led to significant fee reductions*.

16 Jul 2014 - AIST to provide comprehensive response to the Financial Systems Inquiry interim report

The Australian Institute of Superannuation Trustees (AIST) said today it would begin preparing a comprehensive response on key superannuation issues raised in the Financial System Inquiry’s interim report. AIST CEO Tom Garcia said AIST welcomed the Inquiry’s support of a robust regulatory framework for superannuation, its recognition of superannuation’s important role in the economy, and the need to develop clearer objectives for the superannuation system.

3 May 2017 - Response to Productivity Commission Draft Report: Superannuation: Alternate Default Models

AIST identifies key elements for a robust default fund selection process in its response to the Productivity Commission Draft Report: Superannuation: Alternative Default Models.

16 Nov 2016 - Senate Economics: Super reform package of bills

This package of bills contain tax measures proposed in the 2016 Federal Budget. AIST generally supports these measures, noting some practical difficulties to implementation. In this submission, AIST encourages prompt passing of the bills to ensure that sufficient time is given to enable implementation by 1 July 2017.

21 Oct 2016 - Tranche 3 of superannuation reform draft bill

The third tranche of superannuation reform will implement a lower annual non-concessional contributions cap, an account balance cap on non-concessional contributions and streamlines release authorities for Division 293 taxation. AIST notes the dependence of these measures on timely and accurate data being held by the ATO, but supports these measures and their early consideration by Parliament.

20 Oct 2016 - Response to Statement of Issues: Link’s possible acquisition of Pillar

The Australian Competition & Consumer Commission (ACCC) has issued a Statement of Issues (SOI) regarding the possible acquisition of Pillar by Link Administration Holdings Ltd. AIST made a submission during the targeted consultation stage which contained our thoughts in regards to the proposed acquisition. We have considered the SOI and in this submission, we restate the comments that we made previously. Our previous submission is available here.

7 Oct 2016 - External Dispute Resolution Framework

The Government’s review of the financial system’s external dispute resolution framework must carefully consider the needs of consumers. Due to the growth of the superannuation sector the dispute resolution framework must continue to be well equipped to deal with consumer demands and AIST believes that there is scope for improvement. AIST is not opposed to the establishment of a triage service, or a single disputes handling body.

2 Sep 2016 - Response to request for submissions: Link’s possible acquisition of Pillar

While taking a neutral position on commercial matters, AIST notes that superannuation funds have increasingly limited alternatives for the provision of superannuation administration, with there being constraints to insourcing. There is already a high level of market concentration from any perspective, and any increase could also increase systemic risks. New market entrants are possible, but not known. The charts forming part of this submission are also available as a separate paper.

29 Jul 2016 - Data Availability and Use - AIST response to Productivity Commission Issues Paper

Effective use and access to superannuation data is integral to the efficient functioning and integrity of the superannuation system. Superannuation data issues have been raised in previous inquiries and steps have been taken to address especially by the ATO, but significant recurring problems – including all of those identified in the Productivity Commission issues paper – remain and require a higher priority and integrated whole-of-government focus.

17 Jun 2016 - Technology neutrality – meeting notices and materials proposals paper

This submission is AIST's response to the Government's plans to modernise financial regulation rules around the distribution of materials taking into account recent tech developments.

20 May 2016 - CP 254: Digital financial product advice

In this joint submission with Industry Super Australia (ISA), AIST supports the introduction of guidance specific to digitally provided advice that ASIC has issued. We support the clarity that the draft regulatory guide provides, however have recommended that guidance be expanded to include additional issues, including scaling advice, triage and IT outsourcing.

27 Apr 2016 - CP 255: Remaking ASIC class orders on financial services disclosure

AIST has supported the remaking of two class orders dealing with product disclosure statements.

30 Mar 2016 - CP 253: Remaking and repealing ASIC class orders on dollar disclosure

This consultation paper sets out ASIC’s proposals to remake class orders [CO 04/1431], [CO 04/1433] and [CO 04/1435] on dollar disclosure, with the repeal of class orders [CO 04/1430] and [CO 04/1432]. AIST generally supports the proposals contained in this consultation paper. However, we believe that the relief presently provided for periodic statements in [CO 04/1435] is not appropriate and recommend that it no longer apply.

18 Mar 2016 - CP 251: Remaking class order on financial product advice – exempt documents

AIST supports the proposal to continue the relief contained in Class Order 03/606 [CO 03/606] beyond the sunset date. We agree that the relief provided is sensible and should be retained.

2 Mar 2016 - CP 247: Review and remediation programs and changes to record-keeping requirements

AIST supports the proposed ASIC guidance. The guidance would benefit from a stronger focus on independence of reviewers, as well as transparency and accessibility. The focus on whether a matter is systemic may provide a disincentive for licensees to positively act on issues that are easily addressed through a regular profiling program.

19 Feb 2016 - Exposure Draft TPB Information Sheets TPB(I) D30/2015 Cloud Computing and TPB(I) D31/2015 Confidentiality

AIST welcomes guidance for persons providing tax (financial) advice services to members of not-for-profit superannuation funds. We support this guidance but note that ideally, APRA should be consulted to ensure consistent guidance from regulators. AIST also takes the opportunity to remind the TPB that reconciliation of initial disclosure, consent and information gathering processes between TASA and Corporations Act requirements should be prioritised.

12 Feb 2016 - CP 249: Remaking ASIC class order on generic financial calculators

AIST supports the proposal to remake the class order on generic financial calculators, particularly given that the class order would otherwise be ‘sunsetted’. However, AIST believes that a better result going forward would be to examine both generic financial calculators and retirement income projections together. In this regard, AIST urges a review of retirement income projections, in line with the Government supporting the FSI recommendations in this regard. AIST undertook research into financial calculators and retirement income projections in 2014, in conjunction with VPR. Our research is available here.

25 Jan 2016 - Improved Superannuation Transparency

While AIST strongly supports the greater alignment of MySuper and Choice disclosure through the introduction of Choice dashboards, AIST is concerned that certain products (including platforms and legacy products) – in which there is considerable member money invested - are excluded. Alignment of MySuper and Choice is needed to protect members and ensure greater superannuation system efficiency. Greater alignment of Portfolio Holdings Disclosure to consumer disclosure to capture interposed vehicles is also needed.

24 Dec 2015 - Raising professional standards of financial advisers

AIST supports the proposed requirements for financial advisers to require a bachelor’s degree, a professional year and the passing of an exam. We also support the requirement of an industry-wide code of ethics administered by a body chosen by the Minister. AIST submit that the transitional provisions must ensure that practitioners have appropriate time to comply.

20 Oct 2015 - Unclaimed super changes (draft regulations)

AIST welcomes the exclusion of members using electronic means to communicate with their fund from being lost members, and the capacity for ERFs to transfer balances to members’ active accounts without their consent. However, the removal of lost member requirement to be ‘employer-sponsored’ should exclude ERFs transferring balances into active accounts. Overall, however, AIST call for a complete overhaul of lost and unclaimed super rules as they are unnecessarily complicated, confusing and not in members’ interests.

28 Sep 2015 - Draft spring repeal day bill

AIST supports the ATO being able to pay superannuation directly to persons with a terminal medical condition, and the eventual removal of the Lost Member Statement, but submits the LMS removal should be delayed by one year in in order to avoid a gap in lost member reporting and improve the quality of reporting. AIST also calls on the Government to simplify and streamline lost, uncontactable and unclaimed legislation.

8 Jul 2015 - Amendments to AML/CTF customer identification rules

AIST broadly supports the proposed amendments to Chapter 4 of the AML/CTF rules which relate to customer identification. We have noted in passing that there will be a cost incurred with the proposed changes to the safe harbour requirements. We also note that we have a preference for these changes not to be retrospective for administrative reasons.

15 Apr 2015 - Simplifying when a standard choice form is to be provided

AIST supports measures to simplify superannuation administration for employers. Removing the obligation to provide a superannuation choice form to temporary residents is not opposed, but the objective will be more efficiently achieved through the Government’s Single Touch Payroll initiative. Access of temporary residents to superannuation must be maintained, along with measures to avoid the unnecessary duplication of accounts.

31 Mar 2015 - AIST releases submission to final FSI report

AIST’s response to the Government on the Final Report of the Financial System Inquiry (FSI). The FSI Final Report makes a number of recommendations about superannuation and canvasses a range of policy options.

18 Mar 2015 - Treasury draft regulations – fairer taxation of excess non-concessional contributions

AIST supports these draft regulations, which give effect to the measure to allow members to withdraw excess non-concessional amounts and associated earnings.

16 Mar 2015 - ASIC Consultation Paper CP 227 – Disclosure and reporting requirements (29QC)

AIST supports ASIC’s proposed class order relief and guidance (Option 1) on s29QC consistency, and proposes measures to improve consumer comprehension and protection through comparable disclosure across all superannuation products.

27 Feb 2015 - RG 97 review – Fee and cost disclosure in PDSs and statements

AIST welcomes ASIC’s review of RG 97 and strongly supports ASIC’s work on improving disclosure of fees and costs. We recommend that RG 97b could be further improved through clarifying interposed vehicles, disclosing actual performance fees, not carving out listed vehicles, prescribing calculation methodologies and aligning with APRA reporting requirements. AIST also supports better disclosure of related party payments and a separate review of insurance disclosure.

26 Feb 2015 - Exposure draft TPB(I) D25/2015 – Sufficient experience for tax (financial) advisers (transitional)

The exposure draft issued by the TPB explains how the Board will interpret ‘sufficient experience’ and ‘competent standard’ for the purposes of registration as a tax (financial) adviser during the transitional period. AIST welcomes this guidance.

26 Feb 2015 - Exposure draft TPB(I) D25/2015 – Relevant experience for tax (financial) advisers

The TPB exposure draft information sheet outlines the relevant experience requirements for registered tax (financial) advisers. AIST supports the requirements as drafted in this sheet and welcomes this as vital guidance.

9 Feb 2015 - 2015-16 Pre-Budget submission

AIST’s pre-budget submission discusses a range of measures that we believe are in the public interest. Issues raised in our submission include improving the fairness of superannuation, reviewing the rules associated with the age of superannuation fund members and the fairness of existing arrangements for employees, as well as the transition to 12% SG. We also raised the question of inconsistencies associated with the financial supervisory levies and recommended an increase in funding to Indigenous identification schemes.

9 Feb 2015 - ASIC – CP 226 – Remaking class orders on secondary services and general advice

AIST strongly endorses the process of sun-setting legislative instruments after 10 years, unless action is taken to review them. While CP226 covers matters which are the subject of various reviews, these are outside the scope of CP226. Accordingly, AIST supports the renewal of CO 05/835, CO 04/1572, CO 04/1573 and CO 05/1195.

30 Jan 2015 - ASIC – CP 224 – Facilitating electronic financial services disclosure

AIST strongly supports the use of electronic disclosure, and would welcome the implementation of options 1-3 as outlined in CP224, including the opportunity to develop more innovative PDSs. AIST estimates that between 25-50% per annum of current communication costs could be saved. AIST recommends that a Working Group be established to help develop greater guidance, including consumer testing outcomes, defining e-addresses and electronic delivery, and refining storage, retrieval and archiving of electronic materials.

19 Jan 2015 - APRA – Draft Prudential Practice Guide SPG 223 Fraud Risk Management

AIST supports practical guidance on fraud risk but this should be consistently provided for banking, insurance and superannuation. The PPG should also address bribery, corruption, IT and outsourcing fraud risk, especially administration-related, in more detail, and provide more clarity about expectations and useful case studies.

17 Dec 2014 - Enhanced register of financial advisers

AIST welcomes these draft regulations as vital to consumers of financial advice. AIST supports the need for an enhanced register of financial advisers. However, we recommend that this be made through legislation rather than by regulation, given the seriousness of lack of proper prescription to protect consumers. We believe that additional information should be required to assist investors, and would support the inclusion of Financial Services Guides (FSGs) as part of the register.

5 Dec 2014 - Scrutiny of financial advice enquiry

AIST welcomes this Senate Economics inquiry into the scrutiny of financial advice. AIST recommends higher education standards, ongoing professional development and independently regulated codes of conduct combined with better resourcing of regulators. Penalties for poor advice should be reviewed to ensure they better repair customer impacts. In light of recent scandals and the lack of consistency, consumers deserve better.

6 Nov 2014 - SuperStream draft regulations - contributions pass-through

AIST supports the regulation of this requirement, and makes suggestions to improve its operation, in particular: - About 31 March 2015 there should be a mechanism allowing the contributions pass through start date of 1 July 2015 to be confirmed or delayed by up to one year. - There should be further, coordinated and consistent practical guidance provided in the explanatory statement and by the ATO. - The regulation should provide a safe harbour from prosecution during its first year of operation.

17 Oct 2014 - Draft ASIC Class Order: Disclosure of Fees

AIST is pleased once again to consult with ASIC on the subject of fee and cost disclosure. This round of consultation is public, and relates to a draft Class Order aimed at clarifying the requirements for superannuation and managed investment products. The draft Class Order stems from ASIC’s report REP 398 Fee and cost disclosure.

15 Sep 2014 - APRA – Draft reporting standards for select investment options

The Australian Prudential Regulation Authority has issued a draft reporting standards and Discussion Paper seeking views on reporting standards for all RSE licensees to report information in respect of certain non-MySuper investment options, which are referred to as select investment options.

15 Sep 2014 - Senate Economics – FOFA Amendment Bill_2nd inquiry

This is the second inquiry on a bill before parliament to modify certain parts of the Future of Financial Advice (FOFA) reforms that were implemented last year. Changes include amendments to the adviser best interest duties, changes to conflicted remuneration and modifications to grandfathering arrangements.

1 Sep 2014 - SuperStream – pass through of employee details

In August 2014, Treasury commenced consultation on new draft regulations. Specifically, the draft amendment will require that if a superannuation fund offers a MySuper product then that superannuation fund is required to pass on contributions data it receives from any of its default employers relating to any other superannuation funds.

29 Aug 2014 - CP 221 – OTC derivatives disclosure

Derivative transaction reporting is the reporting of over-the-counter (OTC) derivative transaction information to trade repositories, and is a key element of the OTC derivatives reform agenda agreed to by the G20.

26 Aug 2014 - Response to Financial System Inquiry Interim Report

The Financial System Inquiry, chaired by David Murray, has released its interim findings in to the financial system of Australia. This is AIST's response to these findings.

6 Jun 2014 - National identity proofing guidelines

The Attorney-General’s Department has sought consultation on proposed new identity proofing guidelines designed to outline a best practice, risk-based approach to verifying the identity of a person by government agencies. The guidelines may also be useful for other government agencies, private sector or non-government organisations that undertake functions that require the verification of a person’s identity.

4 Apr 2014 - ATO – Revised transition schedule SuperStream standard

A revised draft of Schedule 1 – Transitional arrangements to the Superannuation Data and Payment Standards 2012 was made available for consultation, based upon feedback from industry since the release of the first consultation draft in December 2013. This draft builds on the previous draft by providing greater flexibility in arrangements for the transition-in process.

19 Mar 2014 - AUSTRAC – Revised draft AML/CTF rules relating to customer due diligence

In May 2013 a discussion paper titled Consideration of possible enhancements to the requirements for customer due diligence was released. The purpose of that paper was to seek stakeholder views on current industry practice and the need for amendments to Australia’s anti-money laundering and counter-terrorism financing (AML/CTF) customer due diligence (CDD) regime. Revised draft rules have been prepared in response to that discussion paper, and draft rules that were released in late 2013.

3 Feb 2014 - ASIC: CP 219 – Keeping superannuation websites up to date

This consultation paper from ASIC outlines options for the new requirements of section 29QB of the SIS Act for ensuring that fund websites are kept up to date, including remuneration and proxy voting disclosure.

24 Jan 2014 - AUSTRAC: Draft AML/CTF rules relating to customer due diligence

In May 2013 a discussion paper titled Consideration of possible enhancements to the requirements for customer due diligence was released. The purpose of that paper was to seek stakeholder views on current industry practice and the need for amendments to Australia’s anti-money laundering and counter-terrorism financing (AML/CTF) customer due diligence (CDD) regime.

20 Jan 2014 - ATO: Amendments to transitional arrangements, superannuation data and payment standard

This is a consultation draft provided by the ATO, which extends the timeframe for transitional arrangements, and provides an induction process to support the implementation of employer contributions in the Superannuation Data and Payment Standards 2012.

2 Jan 2014 - ATO SIRN: Verification of SMSF members and bank accounts

Submission to the ATO’s Superannuation Industry Relationship Network (SIRN), dealing with the specific issue of enabling super funds to verify both a person’s membership with an SMSF, as well as the bank account that belongs to an SMSF.

2 Jan 2014 - ATO SIRN: New employee engagement process

Submission to the ATO’s Superannuation Industry Relationship Network (SIRN), dealing with the specific issue of integration of ATO forms for TFN declaration, choice of superannuation fund and account consolidation at the time an employee commences work with a new employer.

2 Jan 2014 - ATO SIRN: Transfer of small inactive accounts from the ATO

Submission to the ATO’s Superannuation Industry Relationship Network (SIRN), dealing with the specific issue of transfers of small inactive accounts back to active member accounts.

16 Nov 2016 - Lifecycle MySuper Product Fees

This research investigates the relationship between MySuper asset allocations, investment fees and member outcomes. It concludes that the majority of funds use a fixed asset allocation that does not vary by age. Lifecycle options (i.e. investment options which do vary by age) are typically used by retail funds, rather than by not-for-profit funds. Where they are used by not-for-profit funds, de-risking (more conservative investments) usually starts at older ages than in retail funds. Building more conservative investment portfolios at earlier ages will see a reduction in member retirement outcomes.

15 Aug 2015 - Meeting members' advice needs

Australians increasingly recognise the need to save for their retirement, and the risk that they will not have enough super. However, with the system likely to contain $7 trillion in assets within 20 years, it is clear that members’ advice needs will need to be met. This survey, conducted in conjunction with Industry Super Australia shows the growth in the advice offerings of not-for-profit super funds and they rise to embrace this new challenge.

15 Dec 2014 - Superannuation projections: A discussion paper

AIST commissioned research to consider the design and regulatory treatment of superannuation projections. The aim of the research was to explore how the value of static superannuation projections to members can be improved. The research also examines interactive superannuation calculators by way of comparison with static superannuation projections.