Submission to APRA on Prudential Standards for Superannuation

• Date:22 Dec 2011
• Type:Poliy Submission

This submission is in response to the discussion paper issued by the Australian Prudential Regulation Authority (APRA) in relation to prudential standards for superannuation. The submission relates to APRA’s proposed prudential standards and associated guidance material regarding governance-related matters.

The points raised by our submission include:

• In view of the size and significance of the superannuation industry, it is imperative that registrable superannuation entity licensees (RSE licensees) implement and maintain “best practice” governance structures. APRA’s proposed prudential standards and guidance materials represent a positive development in this regard.
• There are still some issues that would benefit from further consideration by APRA including, for example, how to encourage RSE licensees to include independent directors on their boards, the criteria for independence and requirements in relation to the qualifications, knowledge and skills of directors of RSE licensees.
• The new regulatory environment should foster good governance while avoiding the imposition of unreasonable cost and time burdens on RSE licensees.
• To the extent possible, APRA should ensure that the regulation of RSE licensees is consistent with the ASX Corporate Governance Principles and Recommendations, including the “if not, why not” approach.
• The proposed regulatory changes need to be supported by a comprehensive education program for RSE licensees.

Download our submission to APRA on prudential standards for superannuation (PDF 5MB)