Regulatory hurdles that continue to challenge the industry

Regulatory hurdles that continue to challenge the industry

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’ best financial interests.  

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.

We’re here to help!

By Tenaiha Fletcher
HIQ Academy Consultant

SDT: planting the seeds of transparency and accountability

The seeds of APRA’s Superannuation Data Transformation (SDT) project have been sown, and while the industry continues to work hard developing its fields of data (pun intended), we pause to reflect on this challenging, multi-year project and what it will harvest.

Just as our resilient Aussie farmers perform through increasingly complex and accumulating economic, social, environmental and institutional shocks and stresses … so do our super funds. However, we are aiming for more data to prove it!

IQ Group continues to support clients in meeting SDT requirements and navigating one of the most challenging projects that the industry has faced in its history. The project, aimed at driving continuous improvement, addressing underperformance within the industry and ultimately delivering quality outcomes for members, is a third of its way through.

Phase 1 – Complete
The bulk of Phase 1 (which covered the highest priority data issues around choice products and investment options along with expense reporting, insurance arrangements, member demographics and asset allocation classifications) was implemented in September last year.

Phase 2 – In progress
Currently being implemented, the second phase of the project explores new and better approaches to data reporting, across all areas including governance and risk management. The granularity of data collections will increase in order to understand the needs of stakeholders. Also, any issues around duplication, or redundancy of data, will be addressed.

Phase 3 – March 2023
The last phase of the project will review and address any issues with quality and consistency, or unintended consequences of the reporting framework already implemented.

Like other significant projects, the SDT requires a lot of hard work and here’s some of the challenges that the industry is facing:

  • Little capacity to engage with consultations, particularly over the August to September 2022 period due to a number of regulatory changes (such as the expanded performance test).
  • Collecting data from insurers is not directly accessible by funds. Also, the interpretation of insurer details can vary with differences in the default employer data received from insurers.
  • Collecting data from custodians, such as Asset Allocation, is also not always available or may not go to the detailed level expected. Also, custodians are reliant on fund managers for such information.
  • Some data is viewed as ‘confidential’ by funds. For example, expenses incurred in operating the fund.
  • Collecting required data from legacy systems can be difficult as it usually requires the co-operation of other entities.
  • Multiple databases storing data may need to be amalgamated with registry system data and then converted into the required format.
  • Increased pressure to improve practices, keep a low fee base as well as providing adequate returns on member investments – given the scrutiny on improving outcomes for members.

“The data being demanded by regulators is extensive and is only going to grow. APRA is starting to know more about Funds, Trustees, and the products they manage than they do about themselves. If the Trustee/Fund hasn’t already, they need to consider this data as core business, they need to get very good at sourcing, managing, reporting, and analysing data to enable informed decisions for their business and members”.

– Peter McDonald (Principal Consultant – IQ Group)

The SDT initiative is demanding (particularly for an industry that is undergoing increasing mergers and significant change) however, it’s critical for the Regulator, along with all industry stakeholders, to effectively assess the performance of an industry that holds over $3 trillion in member assets and increasing importance in the Australian economy.

With such a large scope, extending to all products and across a wide range of reporting areas, it will be a while yet before members will reap what the industry sows and the project proves it has successfully increased the scrutiny, analysis and accountability of super. However, APRA intends to use the data in MySuper and Choice heatmaps, super fund performance assessments, the YourSuper comparison tool, publications, and prudential supervision and this goes a long way to creating a transparent industry that acts in the best interests of members and also helps government make informed decisions when it comes to changes to super.

With all this considered, perhaps we shouldn’t judge the harvest (from this particular project) by what it reaps, but rather by the seeds that it plants?

By Jocelyn Adolphe, IQ Senior Consultant

The Super Horizon

IQ Group is always on the lookout for what might change in the future. For the most part, superannuation was not a major talking point during the election. That all changed with the Liberal announcement of their Super Home Buyer Scheme.  As the final results are still coming in, we pause to consider the ‘super horizon’ under a Labor Government.

Already on the road (for 1 July)

The following measures, legislated under the previous government, are not going to be changed by Labor:

  • SG increase to 10.5% (with continual increases to 12% in 2025);
  • scrapping of the $450 per month wage threshold;
  • downsizer contribution minimum age drop from 65 to 60, as a measure to increase housing stock for families (Labor will also legislate to drop this further to age 55 in line with election promises); and
  • removal of the work test for those aged 67 to 74 years (inclusive).

Labor election promises to be implemented:

  • extend eligibility for the senior card (matched Coalition promise);
  • freeze pension deeming rates (matched Coalition promise); and
  • review benchmarking tests of the Your Future Your Super performance assessment.

On the horizon

The Labor government may also consider:

  • super for paid parental leave (not likely for a while yet as Labor currently cites budgetary repair concerns as a reason);
  • improved access and fairness of the superannuation structure for women; and
  • various protections around eligibility, unpaid superannuation benefits and contractual arrangements (that perhaps fall more into the industrial relations bucket but have an impact on the super industry).

Ruled out

  • Liberal’s announcement of a Super Home Buyer Scheme allowing first home buyers to invest up to 40% of their super (up to a maximum of $50,000) – criticised by Labor during the election. Labor had an alternate policy to promote home ownership that did not involve superannuation.

We are yet to see how the independents and other parties will influence (or not influence) the superannuation landscape under a Labor Government. However, given super has not been a significant focus during the election, its horizon looks relatively unchanged.

The industry will continue to undergo significant mergers and acquisitions and be challenged to implement the many legislative changes post the Royal Commission. However, it may just be able to take a pause, and be given a little more time to focus on consolidation of existing processes, remediation and operational efficiency rather than continued legislative change.

IQ Group look forward to continuing to support and advise our many superannuation clients on the journey ahead and making sure that the super horizon is a bright one .. for the industry and, most importantly, the millions of members that it serves.

 

By David Atcheson, IQ Consultant

Building Super Talent for the Super Industry

HIQ Change and Learning Services (HIQCLS), powered by IQ Group, is proud to introduce you to the inaugural participants of our HIQ Academy. The HIQ Academy provides the superannuation industry with the ‘perfect match’ of skills, experience and knowledge. Participants are chosen based on their existing skillset and experience, and receive tailored training to upskill in either superannuation or business disciplines. It is the ideal solution to current recruitment challenges faced by superannuation funds and providers, and our first round of participants are a fine example of the high quality that HIQCLS can offer the industry now and in the future.

Emma Doyle (Melbourne)

I have over 20 years of business analyst experience across various domains including education, not-for-profit and business franchising. Being part of the HIQ Academy is a fantastic opportunity to deepen my knowledge of superannuation with training and mentoring from the leading consultancy in the super industry.

Having recently completed an Advanced Diploma in IT Business Analysis, the HIQ Academy builds on this training by providing insights into how best to help super funds meet current challenges and the exciting opportunities that new technology offers for improving the member experience.

My new colleagues have been very welcoming and supportive. Being part of the HIQCLS team and having access to the extensive knowledge, skills and experience of IQ Group consultants, is for me a key differentiator.

I’m excited to participate in the HIQ Academy and be given a head start in helping clients with their transformation and change journeys.

Ashley Blackburn (Melbourne)

I come to the HIQ Academy with 4 years’ experience in data analytics, data management and data integrity, as well as the creation, design, and maintenance of reports. After completing my Graduate Certificate of Data Analytics, I have chosen to continue my studies and am now working towards my Masters in Business Analytics at Deakin University.

Participating in the HIQ Academy has given me an incredible opportunity. I am offered the support I need to learn everything about the superannuation industry and connect with a wide range of skilled people. Having this huge support network and the ability to join different clients in a range of roles is perfect as it gives me a balance between a singular structured workload and a variety of projects that I enjoy and thrive in.

My first week as part of the HIQ Academy has really given me a great foundation for the industry and a refresher of concepts I already knew. I am amazed and incredibly grateful for the time taken by everyone, to ensure that we have the best foundations and support. We know we can make the connections we need to succeed no matter what role we take on. The team and culture within IQ Group is unlike anything else I have experienced, and it is clear that this has been driven from the top down through all levels of the organisation. Thanks to this support and guidance, I am really excited about what the future holds.

Lynne Kennedy (Brisbane)

I’ve spent many years in the superannuation industry gaining experience and developing valuable knowledge and skills in super and insurance. I’ve worked for super funds and administrators, all with different cultures and values.

Our introduction to the HIQ Academy has shown me that the IQ Group culture is unique and everyone is willing to offer support and assistance to each other. This collaborative approach has reassured me that I will be able to learn and grow within my new role.

While we are experiencing ‘information overload’ at the moment, I know that there will always be someone there to support me along the way. Accepting this unique opportunity to step into a consulting role, with the help of the HIQ Academy, has been one of the best decisions I could make – not only for my career but for enabling me to pursue the life I want to live.

I’m excited to be part of a company that has the respect and trust of an entire industry, to step out of my comfort zone, and to help clients navigate the complexity of an ever-evolving landscape.

Dave Enders (Melbourne)

Over the last 10 years, I’ve held a number of different roles within the superannuation industry in the administration operations space. The HIQ Academy has been the perfect next step in my career as it introduces me to a variety of new skills and experiences.

During my first few weeks in the HIQ Academy, I have refreshed my superannuation fundamentals and been introduced to business capabilities such as Business Analysis, Project Management and more. I am completing a tailored learning pathway and achieved a BABoK certification. I feel ready for my first client engagement and look forward to gaining even more experience in the industry and, in the future, becoming an IQ renowned consultant.

The support and encouragement from all the team members I’ve met so far has been great, and I’m confident I’ve got the experience, skills and support to succeed.