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Proposed changes to the fees and costs disclosure regime for superannuation and managed investment schemes Jane Eccleston Senior Executive Leader Superannuation Overview Policy objectives for fees and costs disclosure regime Consumers


  1. Proposed changes to the fees and costs disclosure regime for superannuation and managed investment schemes Jane Eccleston Senior Executive Leader Superannuation

  2. Overview

  3. Policy objectives for fees and costs disclosure regime • Consumers who actively seek information about fees and costs receive transparent and useable fees and costs information to help them: – make confident and informed value-for-money decisions – compare products (value of fees and costs information to consumers is lessened if there are significant inconsistencies in the compilation of fees and costs information) – understand the fees and costs charged to them. • The fees and costs disclosure regime is practicable for industry Proposed changes to the fees and costs disclosure regime for superannuation and managed investment schemes 6 March 2019 3

  4. Timeline • Consultation Paper 308 released on • Expected in the second half of 2019 8 January 2019 Release of ASIC’s response to submissions Includes draft updated RG 97 and Sch 10 ASIC and consumer testing conclusions Release amendments response • Start date to be determined • Submissions close on 2 April 2019 Consultation paper seeks industry Follows 3-month consultation period Consultation Regime feedback on timing for implementation period starts • During consultation period • Second half of 2019 onwards Consumer testing of some proposed Consider outstanding proposals Consumer Outstanding changes testing proposals Proposed changes to the fees and costs disclosure regime for superannuation and managed investment schemes 6 March 2019 4

  5. Recommendations ASIC proposes to adopt • Presentation : simplifying and rationalising how fees and costs information is presented (through changes to the fees and costs template and fee example in PDSs and changes to periodic statements) • Reducing data inputs : eliminating the requirement for fee and cost disclosure to include some categories of costs, such as property operating costs, borrowing costs and implicit transaction costs • Consistency : making the fees and costs disclosure for managed investment products more consistent with the fees and cost disclosure for superannuation products Proposed changes to the fees and costs disclosure regime for superannuation and managed investment schemes 6 March 2019 5

  6. Specific proposals •Single line items for administration fees and costs •Transaction costs to be a separate line item in the Super fee and investment fees and costs fee template (shown net of amounts recovered by Transaction the buy-sell spread) •Intrafund advice costs to be included in template costs administration fees and costs •Property operating costs, borrowing costs and implicit transaction costs to be excluded •Ongoing and member-initiated fees and costs to be grouped separately •Counterparty spreads to be included •Periodic statements to be simplified so they •Management costs to become management contain: MIS fee fees and costs and put at the top of the template Periodic •“Fees deducted from your account” •New line-item for buy-sell spread template statements •Ongoing and member-initiated fees and costs to •“Fees and costs deducted from your investment” be grouped separately •“Total fees and costs you paid” Cost of •Single cost of product figure to be included in •Performance fees to include all product/option Performance PDSs for each superannuation product or level performance fees and performance fees product investment option, and each managed charged by interposed vehicles fees investment product investment option •To be calculated based on a 5 year historical information •To be based on a $50,000 balance average Proposed changes to the fees and costs disclosure regime for superannuation and managed investment schemes 6 March 2019 6

  7. Specific proposals (continued) Financial •Costs met through the use of reserves to be included in administration fees and costs or investment fees and •Work with industry bodies to clarify how advisers should Clarifications costs use fees and costs information when giving advice on advisers choice of products •Treatment of amounts paid by third parties or offset against other amounts •Some of the proposals will be consumer-tested Consumer •Testing will focus on the proposed changes to the fees •Re-draft RG 97 so it is easy to follow, logical and clearly RG 97 and costs templates and changes to tool names explains requirements testing •Will also test whether investment fees and costs, and •Explain purposes and context of fees and costs administration fees and costs should be merged into a disclosure single figure •Refine the consumer-facing narrative about the •Maintain existing RG 97 guidance Consumer importance and relevance of fees and costs when Platforms •New guidance on statement for fee template making decisions •Currently undertaking work on platforms. Once education •May include producing information and educational completed, will reconsider whether regulatory settings material for platforms need revision •May include working with industry •Seek preliminary feedback on potential requirements Proposed changes to the fees and costs disclosure regime for superannuation and managed investment schemes 6 March 2019 7

  8. No change but clarifications: Indirect costs •Proposed not to be consumer facing Definition •No indirect cost ratio disclosure Calculation • Further guidance, including on reasonable estimates Interposed •Guidance presentation updated to assist in application vehicles •Different outcomes due to elimination of property operating costs Proposed changes to the fees and costs disclosure regime for superannuation and managed investment schemes 6 March 2019 8

  9. Background: Development of [CO 14/1252] & RG 97 July 2014: Report 398 Fees and costs disclosure: Superannuation and managed November 2015- 30 September 2017: December 2017 and investment products September 2017: December 2014: [CO 14/1252] and December 2018: issued. Four further RG 97 come into November 2015: [CO 14/1252] made Two amendments Found that industry amendments made force to clarify the made to extend Revised RG 97 issued was interpreting the to [CO 14/1252] in requirements dates for compliance fees and costs this period to clarify with certain aspects requirements particular aspects differently, especially in relation to disclosing fees in underlying investment vehicles. Proposed changes to the fees and costs disclosure regime for superannuation and managed investment schemes 6 March 2019 9

  10. Background: External Expert Review • 1 November 2017: Announcement of external expert review • 28 November 2017 : Darren McShane appointed • 24 July 2018: Report 581: Review of ASIC Regulatory Guide 97: Disclosing fees and costs in PDSs and periodic statements ( REP 581 ) released with 34 recommendations and observations Proposed changes to the fees and costs disclosure regime for superannuation and managed investment schemes 6 March 2019 10

  11. Disclosure recommendations ASIC proposes to adopt

  12. Changing superannuation fees and costs template Proposals Benefits • Ongoing fees and costs: • Simplifies disclosure administration, investment, transaction • Aligns MIS and super disclosure • No separate disclosure of indirect • Gives prominence to fees consumers costs pay each year • Intrafund advice incorporated into administration fees and costs • Ongoing fees and costs and member initiated fees and costs grouped Proposed changes to the fees and costs disclosure regime for superannuation and managed investment schemes 6 March 2019 12

  13. Changing managed investment fees and costs template Proposals Benefits • Management costs to be known as • Gives prominence to fees consumers management fees and costs pay each year • New line item for buy-sell spread • Aligns MIS and super disclosure • Rearrange order to group ongoing • Better consumer understanding of fees and costs and member initiated costs of exiting or switching fees and costs together Proposed changes to the fees and costs disclosure regime for superannuation and managed investment schemes 6 March 2019 13

  14. Including cost of product information Proposals Benefits • Include abbreviated cost of product • Helps consumers understand fees and information for each product or option costs of options/products, make offered by the super fund and each decisions and compare investment option offered by the MIS products/options • Based on $50k balance and calculated in the same way as the fee example Proposed changes to the fees and costs disclosure regime for superannuation and managed investment schemes 6 March 2019 14

  15. Simplifying periodic statements Proposals Benefits • Three lines: • Simpler, more useable disclosure – Fees deducted from your account • Easier to understand the fees and costs charged – Fees and costs deducted from your investment • More practicable for industry – Total fees and costs you paid • Align MIS and super disclosure • Renaming additional explanation of fees and costs section (fees and costs details) Proposed changes to the fees and costs disclosure regime for superannuation and managed investment schemes 6 March 2019 15

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