Attached is Deloitte’s submission on APRA’s industry consultation on the “Financial resources for risk events in superannuation” discussion paper (the Discussion Paper). The Discussion Paper outlines proposed enhancements to the current Prudential Standard SPS 114 Operational Risk Financial Requirements (SPS 114).
Our responses to the consultation questions are derived from our experience working with clients to understand and effectively implement regulatory change. In addition, through our experience, we have observed historical and persistent challenges in relation to operational risk management that regulated entities have faced.