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Superannuation transfer planning: Proposed enhancements

Deloitte response to consultation

The APRA discussion paper outlines proposed enhancements to the current Prudential Standard SPS 515 Strategic Planning and Member Outcomes (SPS 515) and Prudential Practice Guide SPG 227 Successor Fund Transfers and Wind-ups (SPG 227).

The introduction of the Annual Superannuation Performance Test and the focus on sustainability across the superannuation market has increased inorganic growth activity amongst funds over the past three years. Whilst the response by some funds to such measures has been to tighten their cost models or make changes to their investment strategy to protect performance, a significant number of other registrable superannuation entities (RSE) licensees used this as the trigger to seek a merger with another RSE licensee to transfer members and assets.

We agree with the strong emphasis that has come through in recent prudential standards on reaffirming the focus on member outcomes and given the trend on transfer activity shows no signs of slowing down, aligning the various prudential standards would support the industry further.

Our response focuses on the key themes that we would consider important to consider when making any updates to SPS 515 and SPG 227 to ensure that this supports the industry, whilst avoiding any unintended consequences which could have the opposite effect of enhancing transfer planning and implementation.


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