Policy & Research Archive

2017 AIST Submissions

January

Friday, 1 December 2017

National Financial Literacy Strategy 2018

AIST supports measures to increase consumer financial literacy skills in order to improve their ability to make good financial decisions. However, the current regulatory framework is deficient and...

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Monday, 20 November 2017

Establishment of the Australian Financial Complaints Authority

This joint submission by AIST and ISA reiterates our disappointment at the decision to dismantle the SCT. AIST believes the transition to AFCA may detrimentally impact the rights of fund members an...

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Friday, 17 November 2017

Strengthening penalties for corporate and financial sector misconduct

AIST supports appropriate penalties for corporate and financial sector misconduct, and generally supports the positions taken in this Paper. We agree that an effective regulator needs to have the ...

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Friday, 3 November 2017

Treasury Laws Amendment (Whistleblowers) Bill 2017

AIST supports the measures in the exposure draft legislation to create a consolidated whistleblower protection framework. The development of a new framework should be accompanied by an examination ...

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Friday, 20 October 2017

Insurance in superannuation code of practice

AIST supports the draft Code of Practice. AIST makes eleven recommendations as part of this submission, based upon key themes that have emerged from consultation with AIST members. AIST notes the l...

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Friday, 29 September 2017

Improving accountability and member outcomes in superannuation measures No.2

AIST welcomes proposed changes which will remove the loopholes that employers can use to reduce the Superannuation Guarantee entitlements of employees that salary sacrifice. AIST also supports the ...

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Friday, 29 September 2017

Improving accountability and member outcomes in superannuation measures No.1

AIST recommends that the outcomes assessment outlined in the Bill be modified in order to reflect the importance of net returns above any other criteria in determining the appropriateness of MySupe...

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Friday, 29 September 2017

Strengthening Trustee Arrangements Bill 2017

AIST is strongly opposed to all the measures in the Bill, and believes it is inappropriate to prescribe a governance model to apply to all funds absent comprehensive empirical evidence that the cur...

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Friday, 29 September 2017

Establishment of the Australian Financial Complaints Authority Bill 2017

AIST submits that it is imperative that superannuation fund members and funds are not detrimentally impacted by the proposal to replace the Superannuation Complaints Tribunal with a new one-stop-sh...

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Monday, 11 September 2017

Strengthening operational governance of RSE licensees

AIST supports the member outcomes test proposed for all superannuation products provided the role of net returns are not diluted. AIST also submits that the existing regulatory framework provides A...

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Thursday, 31 August 2017

ISWG fifth discussion paper - Premium Adjustment Mechanisms

The fifth paper released by the Insurance in Superannuation Working Group (ISWG) outlines how practices sometimes described as ‘profit share arrangements’ apply across the industry and operate in p...

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Friday, 25 August 2017

ATO online super account name display

AIST supports the display of product names in ATO Online, but recommends changing the current listings of product names in the Fund Validation Service to improve fund name recognition by members. H...

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Monday, 21 August 2017

Response to Productivity Commission Stage 3 Issues Paper

This submission reiterates AIST’s strong support for the legislated but not yet implemented system for selecting default superannuation funds. Even without the enhanced quality filter arising from ...

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Friday, 11 August 2017

Salary Sacrifice Integrity Measures

AIST welcomes the proposed changes which will remove loopholes that allow employers to reduce the Superannuation Guarantee (SG) entitlements of employees who use salary sacrifice arrangements. The ...

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Friday, 11 August 2017

Improving Accountability and Member Outcomes in Superannuation

This submission raises a number of concerns about the Government’s Accountability and Member Outcomes Bill. While AIST is generally supportive of measures to improve outcomes and accountability in ...

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Friday, 11 August 2017

Black Economy Taskforce

Submission to the Black Economy Taskforce on increasing superannuation compliance. AIST recommends the Taskforce support existing initiatives (eg, SuperStream and Single Touch Payroll, new supera...

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Friday, 4 August 2017

Housing-related superannuation measures

In response to this exposure draft, AIST points out that the First Home Super Savers Scheme has serious administrative issues that require resolving before implementation could be considered. We al...

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Friday, 28 July 2017

ISWG fourth discussion paper - Data management

This paper from the Insurance in Superannuation Working Group outlines proposals that seek to enhance member insurance outcomes by improving access to timely and relevant information.

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Friday, 28 July 2017

Industry codes in the financial sector

In this submission, AIST argues that the function of codes is to fill gaps, lift standards and promote leading practice rather than being the first line of defence for serious systemic issues. The...

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Thursday, 27 July 2017

Relief application: Disclosure of fees and costs for superannuation products

AIST, in conjunction with ASFA and FSC (on behalf of the RG 97 industry working group) has applied for relief from the dollar disclosure provisions applicable to buy-sell spreads in periodic state...

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Wednesday, 26 July 2017

Online choice of fund design consultation

This ATO consultation seeks feedback on the design of the online choice of fund form. AIST maintains that the form must list the default fund, including details in the current choice form, provide...

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Wednesday, 26 July 2017

Strengthening ASIC’s licensing powers

AIST supports measures which ensure that ASIC has the appropriate powers to ensure that entities applying for Australian Financial Services Licenses (AFSLs) are fit and proper licensees. AIST suppo...

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Sunday, 9 July 2017

EDR and complaints frameworkFramework for Comprehensive Income Products for Retirement

AIST recommends that a post retirement framework be required to be developed by trustees. This would assist trustees in developing a preferred retirement income strategy for their members, in line ...

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Wednesday, 28 June 2017

External Dispute Resolution: Compensation and Redress

AIST has concerns around the use of a compensation scheme of last resort for superannuation complaints notably because unpaid determinations are not an issue within the superannuation sector as sup...

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Thursday, 22 June 2017

Proposed financial levies, 2017-18

AIST notes that the assessment of the levies is difficult, given the current lack of a Cost Recovery Impact Statement. We note that it is difficult to assess whether the levies comply with the Gove...

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Wednesday, 21 June 2017

Review of Fair Entitlements Scheme

AIST supports all efforts to better support employees who may be affected by an employer’s insolvency. We endorse Industry Super Australia’s submission and point to the role that Single Touch Payro...

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Wednesday, 14 June 2017

EDR and complaints framework

AIST and ISA, in a joint submission, have identified key issues regarding the proposal to establish a new external dispute resolution scheme to replace the Superannuation Complaints Tribunal and th...

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Wednesday, 14 June 2017

FOFA post-implementation review

In this joint submission, AIST and ISA argue for removal of exemptions from the conflicted remuneration prohibitions. We also put a case for client fee agreements to be made annually, as opposed to...

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Friday, 26 May 2017

ASIC Supervisory Cost Recovery Levy Regulations 2017 exposure draft

AIST supports the introduction of an ASIC industry funding model. We reiterate our lack of support for any carve-outs (eg the ‘Statutory Levy’) from the Government’s Cost Recovery Guidelines. Giv...

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Friday, 12 May 2017

ASIC Enforcement Review: Self-reporting of contraventions by financial services and credit licensees

An effective breach reporting framework is critical for effective enforcement of the financial services regulatory regime. AIST supports the Review’s proposals to strengthen the breach reporting fr...

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Friday, 5 May 2017

ISWG third discussion paper - Member communication and engagement

The third discussion paper released by the Insurance in Superannuation Working Group (ISWG) outlines options to improve member engagement and understanding of insurance arrangements within superann...

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Wednesday, 3 May 2017

Draft Regulations Innovative Superannuation Income Streams

AIST identifies key elements for a robust default fund selection process in its response to the Productivity Commission Draft Report: Superannuation: Alternative Default Models.

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Monday, 24 April 2017

Super reform – minor and technical amendments

This exposure draft rectifies many of the issues identified during consultation on the new measures introduced as part of the 2016 Budget. AIST strongly supports these changes in principle, howeve...

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Wednesday, 12 April 2017

Draft Regulations Innovative Superannuation Income Streams

AIST welcomes the certainty that these regulations will bring for providers of innovative income streams. These draft regulations would be improved through limitations on unreasonably long deferral...

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Monday, 20 March 2017

RG97 fees and costs disclosure – issues list provided to ASIC

As requested by ASIC in its notification to extend the transition time for RG97, the industry has submitted the attached lists (separated into policy and technical issues).

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Wednesday, 15 March 2017

Design and distributions obligations and product intervention power

In these joint submissions AIST and ISA generally welcome the proposals to impose obligations upon financial product issuers and distributors and to provide ASIC with product intervention powers to...

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Friday, 10 March 2017

ASIC levies draft bills

AIST strongly supports the introduction of an ASIC industry funding model and the move towards greater transparency. However, AIST does not support carve-outs from complying with the Government’s ...

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Friday, 10 March 2017

Transfer Balance Cap and death benefits (Draft LCG 2017/D3)

In our submission on this draft Law Companion Guideline, AIST raises a question around the policy intention of different treatment of death benefit income streams depending on whether these are rev...

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Tuesday, 7 March 2017

Consumer protections in the financial services industry

The Senate Economics References Committee is undertaking this inquiry into consumer protections in the banking, insurance and financial services industry. AIST believes that the numerous exemption...

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Friday, 17 February 2017

Successor fund transfers and wind-ups (draft SPG 227)

AIST thanks APRA for the opportunity to comment on this draft PPG. AIST supports all assistance that can be provided to trustees to facilitate super fund consolidation. Such consolidation will ensu...

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Friday, 17 February 2017

Senate Economics: SG non-payment

Employer superannuation non-compliance remains a serious problem and calls for an automated and systematic response, as well as requiring more resources for managing complaints. AIST argues for ATO...

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Friday, 10 February 2017

Whistleblower protections

The Australian Whistleblower protection framework is in need of significant reform because it fails to adequately protect whistleblowers. Changes to the law are necessary to ensure that those who d...

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Thursday, 2 February 2017

Means testing of retirement income streamsMeans testing of retirement income streams

AIST considers that the role of social security in prioritising Comprehensive Income Products for Retirement (CIPRs) as recommended by the Financial System Inquiry needs to be addressed in this dis...

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Thursday, 2 February 2017

Superannuation reform package regulations

AIST has made a brief submission to Treasury in relation to draft regulations to support the implementation of the new superannuation measures. We have not identified any issues on which we need t...

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Friday, 27 January 2017

External Dispute Resolution: Response to Interim Report

AIST strongly opposes the draft recommendation to transition the Superannuation Complaints Tribunal to an industry ombudsman scheme because it will detrimentally affect consumers and superannuation...

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Tuesday, 24 January 2017

ATO issues guidance on the defined benefit income cap

LCG 2016/D10 provides guidance around how the defined benefit income cap applies to superannuation income stream benefits that are paid from a non-commutable, lifetime pension or lifetime annuity. ...

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Tuesday, 24 January 2017

ATO issues guidance on amendments to the calculation of concessional contributions

LCG 2016/D11 provides guidance around amendments to the calculation of concessional contributions and excess concessional contributions in the Act apply to contributions and amounts allocated by su...

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Thursday, 19 January 2017

Pre-Budget Submission 2017

AIST welcomes the opportunity to present our Pre-Budget submission for 2017-18. We do not endorse superannuation being used for deficit reduction to a greater extent than other industry segments or...

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Monday, 9 January 2017

ASIC-ATO Information sharing

This exposure draft legislation which enables ASIC to share information with the ATO without the need for approval of the Chairperson of ASIC. AIST supports measures to promote the streamlining of...

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