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AIST strongly endorses the proposals to record all complaints, provide reasons and that reporting to ASIC is needed. However, AIST strongly recommends that a complaints data and reporting Framework is needed to ensure that a co-ordinated approach across funds, ASIC and AFCA is taken. The proposed definition of ‘complaint’ needs greater guidance. AIST agrees with the proposal to reduce superannuation IDR timeframes, but seeks discussions regarding how complex complaints such as disability or death claims (which take longer) will be handled. The proposed commencement date needs to be deferred. AIST calls for an industry roundtable.