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AIST welcomes the opportunity to respond to this draft report. AIST agrees that there is no place for long term underperforming funds in the default space. However, we believe enhancing the current Fair Work Commission default selection process and increased APRA scrutiny are the most efficient, appropriate, and importantly the least disruptive ways, to address this issue. The Productivity Commission should address the biggest problem of underperforming choice funds in the retail sector, which is a drag on the efficiency of the super sector. The ‘best in show’ default proposal does not address this. Multiple accounts, balance erosion by fees and underperforming funds are serious issues, which are already being addressed by the APRA Outcomes Assessment Test, new ATO services. This should be enhanced by legislation supporting direct fund-to-fund consolidation of lost super. The Insurance Code should be implemented and be the focus for lifting standards. Regulator benchmarking of fees and returns should be used to assess if funds are delivering fair value and address under-performing funds.