Trustees will need to attend to higher governance standards, while at the same time putting clients first, according to Deloitte superannuation practice principal Ben Facer and associate director Diane Somerville.
Overall, there was a strong theme that trustees must understand the risks and not delegate their responsibility – even though specific functions were delegated, they said, with Stronger Super entailing heightened trustee and regulatory oversight.
“This means that trustees will need to develop a program of ongoing governance,” they said, with governance being a living framework – reviewed, tested, monitored, updated regularly, with standing items on board, committee and management meetings.
Many trustees had already done a gap/impact analysis to determine the impact of the Stronger Super reforms and new prudential standards on their existing fund products and policies and procedures.
Based on this analysis, each trustee would be able to determine in which areas there were gaps that needed to be addressed before they could apply for a MySuper authorisation. This would form an important part of their Stronger Super implementation plan.
During this period of preparing for Stronger Super, trustees should also be engaging with their Australian Prudential Regulation Authority (APRA) supervisors regularly to provide any feedback on any issues arising.
“Trustees should beware the risk of treating governance as merely a compliance exercise to meet the tight deadlines in place for the introduction of MySuper,” Facer and Somerville said, commenting in Deloitte’s “Financial Services Risk and Regulatory Review”.
“Rather, the governance program should be used as a business tool to minimise risk and maximise outcomes for the trustee and the fund, and hence the members.”
On the subject of transition, Facer and Somerville said there should be an “orderly transition” of existing accrued default amounts (ADA) into an authorised MySuper product by no later than 1 July 2017.
Trustees would have to identify ADAs, being amounts invested in the current default option, and amounts invested in other options where no investment choice had been made by the member, for example, former default options or grandfathered investments from mergers.
Facer and Somerville warned that, given the significant amounts and numbers of members affected, “a transition strategy with careful timing and communications is critical”.
They warned trustees to act now, rather than waiting until 2017, because the transition plan must be developed and provided as part of the MySuper application to APRA.
