AIST submits that the superannuation industry is made up of funds with varying ownership structures. Profit-to-member RSE licensees are run solely to benefit members and are not a source of profit to their owners(s) and this should be fully considered in the application to own or control an RSE licensee. AIST has also advocated for additional guidance for what constitutes a change of control for the purposes of these requirements and the need for applicants to demonstrate how various entities within a group structure will be effectively managed and supervised.