Policy & Research Archive

2015 AIST Submissions



Friday, 18 December 2015

IGT review of employer obligations compliance activities

AIST supports the removal of red tape for employers, however we believe that this must not come at the expense of employees’ entitlements. AIST does not support the existing model where a breach m...

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Thursday, 24 December 2015

Life Insurance Reform Legislation

This exposure draft removes the exemption on benefits paid in relation to life insurance products from the ban on conflicted remuneration. AIST supports the removal of this exemption. AIST does n...

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Thursday, 24 December 2015

Raising professional standards of financial advisers

AIST supports the proposed requirements for financial advisers to require a bachelor’s degree, a professional year and the passing of an exam. We also support the requirement of an industry-wide c...

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Friday, 30 October 2015

Senate Economics review of economic security in retirement for women

The superannuation gender gap is a pressing issue. AIST welcomes this review by the Senate Economics References Committee, and believes that this review, combined with the Government’s response to...

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Monday, 26 October 2015

Reforms to Superannuation Governance Prudential Framework

APRA has proposed draft prudential standards and practice guides designed to support the Superannuation Legislation Amendment (Trustee Governance) Bill 2015 which is currently before Parli...

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Tuesday, 20 October 2015

Unclaimed super changes (draft regulations)

AIST welcomes the exclusion of members using electronic means to communicate with their fund from being lost members, and the capacity for ERFs to transfer balances to members’ active accounts with...

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Friday, 9 October 2015

ASIC Industry Funding Model Proposal

Additional funding for ASIC is necessary for it to be a strong and effective regulator, able to fulfil its statutory obligations and community expectations.

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Monday, 28 September 2015

Draft spring repeal day bill

AIST supports the ATO being able to pay superannuation directly to persons with a terminal medical condition, and the eventual removal of the Lost Member Statement, but submits the LMS removal shou...

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Friday, 25 September 2015

ASIC Capability Review of the Australian Securities and Investment Commission

AIST supports this review, however believes that better value would be gained through combining both the capability and funding of ASIC together into a single review. Generally, AIST supports the ...

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Friday, 18 September 2015

Changes to the SG charge

AIST supports existing measures to ensure members’ contributions are paid in a timely manner. The proposed changes reduce the bases of the SG charge shortfall amount and the nominal interest payab...

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Thursday, 10 September 2015

AIST’s final supplementary response to tax discussion paper

AIST is pleased to provide our final supplementary submission to the tax discussion paper. AIST supports a comprehensive review of superannuation and retirement incomes which takes into account th...

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Friday, 14 August 2015

Proposed changes to reporting standards for ABS

AIST welcomes the inclusion of reporting items from SRS 730.0 into SRS 330.0, and the removal of SRS 730.0. AIST strongly believes that the suite of ABS reporting forms needs to be finalised in ta...

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Friday, 31 July 2015

Reforms to superannuation governance – APRA

The Government’s proposed changes to trustee board governance include a proposal to mandate one third directors being independent. AIST does not support this proposed change. Instead, AIST suppor...

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Friday, 24 July 2015

Tax discussion paper retirement incomes review

Expanding on our initial submission to the Tax Inquiry, AIST details a process for a robust and evidence-based review of retirement arrangements, involving a summit on the objectives of retirement ...

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Thursday, 23 July 2015

Reforms to superannuation governance

AIST is pleased to respond to this draft legislation and regulations from Treasury, which will introduce a requirement for funds to have a minimum of one third independent directors, and an indepen...

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Thursday, 9 July 2015

APRA statistics publication and confidentiality

AIST supports the non-confidentiality of fields contained in SRF 540.0 and 710.0 in the interests of a transparent and competitive industry. AIST also supports the proposals contained in this discu...

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Wednesday, 8 July 2015

Amendments to AML/CTF customer identification rules

AIST broadly supports the proposed amendments to Chapter 4 of the AML/CTF rules which relate to customer identification. We have noted in passing that there will be a cost incurred with the propos...

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Wednesday, 1 July 2015

Joint submission: Cooperative, mutual and member-owned firms

Senate Economics is conducting an inquiry into the role, importance, and overall performance of cooperative, mutual and member-owned firms in the Australian economy. AIST has joined with Industry ...

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Friday, 19 June 2015

Changes to assets test

AIST welcomes the inquiry on this Bill. Our comments are limited to Schedule 3 which contains the proposed changes to the assets test. AIST points out that the proposed changes will have a negati...

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Wednesday, 10 June 2015

Proposed financial institutions supervisory levies for 2015-16

AIST welcomes consultation on the collection of financial levies for 2015-16. AIST comments that the proposed levies paper does not appear to comply with the Government Cost Recovery Guidelines an...

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Monday, 1 June 2015

Response to tax white paper

The Government’s tax discussion paper, “Re:think” provides 66 questions on how to reform Australia’s taxation system. AIST’s submission explores the need for principles and objectives for the supe...

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Friday, 17 April 2015

Superannuation data collection by APRA and ABS

AIST wishes to thank both APRA and the ABS for their consultation on superannuation data collection for the ABS. AIST strongly recommends that further consultation take place, based on the outcomes...

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Wednesday, 15 April 2015

Update on regulatory cost savings

AIST welcomes APRA’s update on its regulatory cost savings program. AIST supports the reviews that have been announced as part of this update, in particular the reviews of audit and ORFR requireme...

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Wednesday, 15 April 2015

Simplifying when a standard choice form is to be provided

AIST supports measures to simplify superannuation administration for employers. Removing the obligation to provide a superannuation choice form to temporary residents is not opposed, but the object...

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Tuesday, 31 March 2015

AIST releases submission to final FSI report

AIST’s response to the Government on the Final Report of the Financial System Inquiry (FSI). The FSI Final Report makes a number of recommendations about superannuation and canvasses a range of pol...

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Wednesday, 18 March 2015

Treasury draft regulations fairer taxation of excess non-concessional contributions

AIST supports these draft regulations, which give effect to the measure to allow members to withdraw excess non-concessional amounts and associated earnings.

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Monday, 16 March 2015

ASIC Consultation Paper CP 227

AIST supports ASIC’s proposed class order relief and guidance (Option 1) on s29QC consistency, and proposes measures to improve consumer comprehension and protection through comparable disclosure a...

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Friday, 27 February 2015

RG 97 review – Fee and cost disclosure in PDSs and statements

AIST welcomes ASIC’s review of RG 97 and strongly supports ASIC’s work on improving disclosure of fees and costs. We recommend that RG 97b could be further improved through clarifying interposed v...

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Thursday, 26 February 2015

Exposure draft TPB(I) D25/2015 – Sufficient experience for tax (financial) advisers (transitional)

The exposure draft issued by the TPB explains how the Board will interpret ‘sufficient experience’ and ‘competent standard’ for the purposes of registration as a tax (financial) adviser during the ...

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Thursday, 26 February 2015

Exposure draft TPB(I) D25/2015 – Relevant experience for tax (financial) advisers

The TPB exposure draft information sheet outlines the relevant experience requirements for registered tax (financial) advisers. AIST supports the requirements as drafted in this sheet and welcomes...

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Monday, 9 February 2015

2015-16 Pre-Budget submission

AIST’s pre-budget submission discusses a range of measures that we believe are in the public interest. Issues raised in our submission include improving the fairness of superannuation, reviewing t...

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Monday, 9 February 2015

ASIC – CP 226 – Remaking class orders on secondary services and general advice

AIST strongly endorses the process of sun-setting legislative instruments after 10 years, unless action is taken to review them. While CP226 covers matters which are the subject of various reviews,...

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Friday, 30 January 2015

ASIC – CP 224 – Facilitating electronic financial services disclosure

AIST strongly supports the use of electronic disclosure, and would welcome the implementation of options 1-3 as outlined in CP224, including the opportunity to develop more innovative PDSs. AIST e...

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Monday, 19 January 2015

APRA – Draft Prudential Practice Guide SPG 223 Fraud Risk Management

AIST supports practical guidance on fraud risk but this should be consistently provided for banking, insurance and superannuation. The PPG should also address bribery, corruption, IT and outsourcin...

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