Better superannuation data has already delivered better outcomes for super fund members but there’s been a lot to digest and now it’s time for a stocktake. We take a look at what that means for funds.
Lots of funds have always had members interests at heart, and the long-term outperformance of industry funds is testament to that.
But not all funds! The industry as a whole has needed a push-along to focus on getting the best retirement outcomes for their members.
That’s where data reporting to underpin performance assessment comes in.
The information super funds are legally required to send to APRA is the fuel that drives performance assessments and superannuation product Heatmaps, and supports its supervisory activity.
Quality data allows APRA to scrutinise and reliably compare fund and product performance, and gives the Government greater visibility of super funds.
The payoff from better data reporting
Super fund members have benefited greatly from information on investment performance and fees being presented in a transparent and comparable manner.
As a result, members are better able to choose lower-fee or better performing products.
Even more significantly, the promoters of many higher fee and poorly performing products have decided to improve or close in response to having the spotlight shone on them. This has improved outcomes for millions of superannuation members.
Forget about all the bells and whistles that some funds have liked to showcase. To rephrase the old saying “It’s the (net) returns, stupid”.
The renewed focus on returns driven by good investments, good governance, the newish “members best financial interests duty,” and supported by better data reporting, has delivered returns
Over the past decade, the amount of information sent by funds has increased enormously, and all funds and administrators have made enormous investments in their data reporting teams and enhanced data reporting processes.
We’ve been working with many funds and service providers on these projects for many years and realise just how big and daunting these projects are.
Managing a data reporting delay
It hasn’t been all smooth sailing, however.
There’s been a lot of two steps forward, one step back, as implementation timetables for both new reporting requirements and new data collection arrangements have been regularly rejigged, and APRA has sometimes struggled to deal with the data they have been sent – especially when some of it’s of poor quality.
One year into its five year data strategy, APRA is pushing the pause button on much of their data reporting and collection program while they undertake an external review. This is with a view to adjusting sequencing, timing and scope of collections to ensure successful implementation by both APRA and industry.
APRA intends to commence formal consultation in November on reporting for investments, registrable superannuation entity (RSE) and RSE licensee profile, and RSE licensee financials, but is postponing consultation on RSE licensee operations, and other reporting standards relating to financial data and cross industry proposals for non-financial risk data collection, which were originally intended to commence in November.
The APRA Roadmap that previously included timelines for consultation, the APRA response, indicative industry build, and the dates for earliest commencement of reporting on topics previously listed for November have been removed.
Putting your best foot forward
The lack of certainty about the next steps for data reporting challenges super funds to understand, assess and respond to a changing situation, in what our CEO Brian Peters call the “sandy regulatory landscape”.
Super funds don’t want to waste resources meeting reporting requirements that might change, but at the same time, everyone’s a winner when data quality is improved, and reporting is accurate, timely and complete.
Funds focused on filling in their data gaps now are going to be the best place to be able to show off – to members, APRA and the community – their suite of high performing products, and demonstrate their operational efficiency and good governance.
In Super we have grown up with closed loop service environments that have provided us with: Resilience, Scale, and Distributed investment in technology.
And as recently as 18 months ago IQ ran a masterclass in Super fund operating models, which for its time was quite relevant …
However, time, the world, and technology has moved on.
Wave 2 mergers, competition, advice reform, consolidation of service providers, and demand for data have all set the idea of a steady target state under pressure.
It also raises legacy product and insurance complexities that somehow seem to defy our best efforts for standardisation.
Our thinking now is that we need to look at operating models not as destinations, but as change engines that enable us to regularly re-evaluate and evolve our approach.
Stanley McChrystal called it, building for Complexity not for Complication.
The new operating model paradigm challenges us to identify the key factors which help us to understand, assess and respond to our changing environment. All within the context of dynamic strategy, competition and a sandy regulatory landscape.
So, what makes a successful and continuously evolving operating model, admin strategy and technology service platform?…
Culture
Not engagement, benefits, or retention, but the unwritten instructions that drive most of our activity. Research demonstrates that when we map a process, it covers less than 50% of the actual activity within a team. Culture guides the rest, and can be the difference between standing still, and evolving.
Culture (supported by key operating intelligence) supports the adaptive organisational business model and direction.
So will AI bridge any culture gaps? Not likely. Centaurs (AI enhanced human teams) still require us to set in place a model for decision and action that is focussed on our goals and reflects our ethical and commercial compass.
Automation for its own sake just takes you to the wrong place, faster.
The Treasurer, Jim Chalmers, has delivered the 2023-2024 Federal Budget, with the key theme of fairness, as it largely focuses on the provision of assistance to Australians to help them manage the cost of living, and doing so in a sustainable way.
There are several welcome changes to the announcements aimed at assisting the vulnerable – aged care workers, single parents and parents who require access to childcare services to name a few. Indirectly, these measures could be seen as a benefit to women who predominantly fill these categories, though the payment of SG on paid parental leave remains a missed opportunity.
From a superannuation perspective, compared to previous budgets, only a few announcements were made (noting that these measures have not been legislated). These are:
Better targeted tax concessions – higher tax on superannuation balances of $3 million or more. Individuals with superannuation balances exceeding this amount will have to pay an additional 15% on the earnings of their super account that exceed $100,000. (Start date of 1 July 2025) These changes will impact:
members – those with balances exceeding $3m (estimated to impact 0.5% of accountholders – approx. 80,000 people when implemented) as they will now incur additional tax; and
superannuation funds – required to update systems to administer the additional 15% attributed to the earnings corresponding to the proportion of balances exceeding $3m (i.e. a total of 30% tax on earnings related to assets above $3m whilst assets below $3m continue to be taxed at 15%.
Increased frequency of SG payments – aligning payment of SG contributions with payroll frequency. This aims to deliver benefits to employees, not only by making it easier to track their contributions, but also to boost retirement savings due to funds being invested sooner. (Start date of 1 July 2026) This will impact:
employers and payroll providers – who will need to manage cashflows to account for the payment of superannuation being aligned to the payment of wages;
members – whose contributions will be paid more frequently allowing them to benefit from compounding of interest over their working life;
superannuation fund administrators – who will need to review and manage changing workloads and cashflows due to the increased frequency of contributions received;
the ATO – who will be required to oversee and enforce the changes to superannuation contribution payments.
Changes to Non-Arm’s Length Income (NALI) and Non-Arm’s Length Expenditure (NALE) provisions – solely applicable to income and expenditure by super funds. Changes to NALI and NALE will impact:
SMSFs and APRA regulated funds – by limiting the income that is taxable as NALI to twice the level of a general expense;
large APRA regulated funds – as they will be exempt from the NALI provisions for general and specific expenses incurred by the fund and the exclusion of contributions from being taxable as NALI; and
all funds – as expenditure that occurred prior to the 2018/19 income year will be exempt.
At face value, the superannuation changes announced appear straightforward, whilst also providing a reasonable transition period for implementation. History tells us though that ‘the devil is always in the detail’ so, although the timeframes appear far in the distance, discussions with relevant vendors is always better commenced sooner rather than later.
The new year brings new Graduate Consultants to IQ, carefully chosen from an impressive talent pool to be just the right fit for our team and our clients. We take great pride in kick-starting people’s careers in finance and building talent for the industry. As you will read below, our two recruits well and truly have the foundations for being accomplished IQ consultants and we welcome them to the IQ Group team.
Andi Metali
After completing a Bachelor of Business last year, majoring in Economics and Finance, I joined IQ Group as a Graduate Consultant looking to kickstart my career in the superannuation space. Throughout university, I worked part time as a cinema manager for 5 years, using my strong communication and leadership skills to help guide staff into making a memorable experience for guests.
I sought out IQ Group’s Graduate Program after a recommendation from a prior grad, citing the program as a fantastic way to gain entrance into full-time work by diving into the intensive program, playing on the strengths I had developed throughout my youth.
IQ Group was incredibly patient with us new grads, helping us assimilate into the company by going above and beyond what was necessary to ease us in and make us feel comfortable. The staff at every level were immensely receptive and give the impression that they truly want what is best for us – which is to be able to grow as people. I’m excited to be able to start with IQ Group, and very much look forward to working with the team!
Taylah Heise
I recently joined IQ Group as a Graduate Consultant after completing my Bachelor of Commerce, majoring in Management. During my studies I spent my time working as an Administration Officer for a local Victorian TAFE, where I had developed fundamental customer engagement and service skills. After completing my degree, I spent a year working for Adobe which was where I was fully able to utilise core analytical skills as well as find a passion in learning and development processes.
I was drawn towards IQ Group for a number of reasons, primarily for the intensive Graduate Program they provide which would expose me to critical skills and a wide client base, but also their core value in working as a team to deliver quality results.
Within the first day at IQ, my fellow graduate and I were welcomed openly by the team as well as the executives, who openly answered our questions and explained the key aspects of the role, and the warm culture of the company. I am eager to begin my journey at IQ Group and am looking forward to this chapter of my career.
IQ Group provides graduates with their career ‘head start’ through training and career development. We provide the right tools and training to ensure our graduates can achieve career success through mentoring, support and e-learning. Our graduates receive:
a structured program with an initial intensive skills development training boot camp, providing Business Analysis, Project Management, Data and Change skills, as well as RG146 qualification;
12 months of formal mentoring by a Principal Consultant;
great exposure to a variety of work environments and a network of professionals within the industry; and
valuable experience on a wide range of engagements working with a great IQ Group team and clients.
While Australians return to a sense of normalcy following the initial impacts of the pandemic, university students everywhere are looking for opportunities where they can make an impact. That was me just a short time ago but … how many job seekers are familiar with the opportunities present within the super and wealth management industries?
I joined IQ Group in February 2021 as a Graduate Consultant and, soon after, completed an intensive induction which covered consultancy skills, superannuation, business analysis, and regulatory compliance requirements for registrable superannuation entities.
Prior to joining IQ, my own experience with superannuation were the forms I had to fill out when signing up for various hospitality gigs while at university studying a Bachelor of Commerce. But of course, super plays a key role within the Australian economy. As the fourth largest industry in the country*, and with assets currently around $3.4 trillion**, it accommodates services operating across multiple specialties including investment management, insurance, risk and compliance, IT, administration, finance and accounting, marketing and communications … and the list goes on.
Transitioning from a Grad to an Associate Consultant has been rewarding and challenging and I would like to share with you a key highlight of my experience.
During my first year, I was provided the opportunity to contribute towards a high-profile data remediation project. This project was executed with a team of nine consultants and each team member brought to the table a deep knowledge of super along with a diverse variety of skills. As a Graduate, this was an incredible opportunity to learn and develop within a highly capable team and be part of a large project.
Within this project, I was able to make a material impact through the creation of complex models utilised to identify and remediate members. I was also able to develop strong relationships with stakeholders, both internally and externally. It was an extremely challenging undertaking, due the wide variety of complex business rules that needed to be considered.
I look back fondly at this formative period in my career, as IQ gave me the opportunity and support right from the outset to develop my analytical and stakeholder management skills while delivering a successful outcome for the client.
I am grateful to work in an environment where I am constantly learning new approaches to tackle problems, and working alongside such a highly capabable team.
As a graduate, or a young professional, wanting to gain exposure into one of Australia’s largest industries and make an impact, I would definitely apply to IQ or reach out for a conversation.
By Matthew Thynne Associate Consultant
* IBISWorld – Industry Market Research, Reports, and Statistics. (2022). IBISWorld. Retrieved August 23, 2022, from https://www.ibisworld.com/australia/industry-trends/biggest-industries-by-revenue/
** Super Statistics – ASFA. (2022, May). ASFA. Retrieved August 23, 2022, from https://www.superannuation.asn.au/resources/superannuation-statistics
The recent amendments to Prudential Standard SPS250 are further proof that APRA is keeping the superannuation industry on its toes when it comes to members’ bestfinancialinterests.
The Standard requires Registrable Superannuation Entities (RSEs) to further protect members from potential adverse outcomes caused by conflicted life insurance arrangements and, in doing so, include robust decision-making in the negotiation and ongoing review of insurance arrangements.
There is a short implementation window for the revised prudential updates and IQ Group is supporting clients in this regard.
APRA’s primary focus for trustees to select, manage and monitor their group insurance policies will have a significant impact on operations. Here’s our insight into what has changed and where the greatest impact will be felt.
Independent Certification The first change to note is the requirement to obtain an independent certification to review related party insurance arrangements before entering contracts, or materially altering, an insurance arrangement on a 3 yearly basis.
This is particularly relevant to super funds that are within vertically integrated structures that also deliver group risk insurance.
APRA has made this core change to the standard to ensure that trustees are aware of anything, within insurance arrangements, which may not be in the members’ best financial interest and that an independent external party is engaged to avoid any perceived conflict of interest in confirming this determination.
Priority or privilege The Standard also requires trustees to avoid any conflicts based on “priority or privilege”. So, what does priority or privilege actually mean?
The changes state that a “priority or privilege” may occur where:
the terms of an arrangement provide an insurer with a current or future competitive advantage relative to other insurers, or
the terms of an arrangement favor the insurer relative to the RSE licensees or beneficiaries.
It applies when an insurer is not a connected entity of an RSE licensee but has been selected to provide insurance cover for the RSE’s members.
The recommendations from the Royal Commission outlined that, regardless of the related party status of a group insurer (connected or non-connected), the safeguarding of members’ interests remains the number one priority. Increasing the emphasis on members interests has been an increasing priority for APRA in the past few years.
APRA considers that independent certification is most likely to be provided by auditors, actuaries, or legal firms qualified to offer an unbiased, informed, and independent opinion. However, this will likely result in increased compliance and governance costs which could, in turn, increase administration fees for fund members.
The change will require a fresh new level of transparency when funds arrange and manage group insurance contracts.
Data Management Another important change is the requirement for RSE’s to strengthen data management and improve analysis of member outcomes across different cohorts. RSEs are required to use the improved analysis to ensure that the type and/or level of insurance offered does not inappropriately erode the retirement income of beneficiaries.
The timeframes around SPS 250 amendments are critical and impacts will be noticed for those insurance arrangements ending after 1 January 2023 (for RSE/Insurer connected entities) and after 1 January 2025 for (non-connected entities).
The time has come, and APRA is expecting RSEs to get their “insurance house in order”. IQ Group are already working with clients to implement these amendments and ensure they meet their obligations within the very short timeframes.
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