Speaking at the SunGard Financial Industry Forum in Sydney yesterday, Mr Braga said a big "data dump" of a super fund's entire portfolio holdings would not work in practice.
"It works theoretically, because at least it’s only going to your regulatory supervisor who can then peel it back together and put it back into some semblance of reality," Mr Braga said.
But providing thousands of lines of portfolio holdings data directly to the average superannuation investor would only cause confusion, he said.
To illustrate the problem, Mr Braga highlighted the trivial example of "Greece blowing up".
"If I’m publishing my global equities book and it looks like I’ve got all these Greek positions but I’ve gone and hedged them out, what do I show?
"Do I show the effective exposure, which means I’ve got nothing in Greece? Or do I show the two [postions] alongside each other because there’s counterparty risk in the derivative position?" Mr Braga asked.
The average person would not be able to understand the complex positions held by a typical institutional investor, he said.
"So we’ve got a little bit of moral hazard here. We say we’ve got all this data, and we say it’s available, but is it actually fit for purpose?
"We’ve got to tread carefully through [this] and I think it’s incumbent on our industry to inform the wider stakeholder group of some of that potential hazard," Mr Braga asked.
The superannuation portfolio holdings disclosure rules were originally intended to be part of the Stronger Super regime that was put in place by APRA on 1 July 2013.
However, after consultation with industry that saw Treasury receive 90 submissions, the requirement to disclose portfolio holdings was deferred until 1 July 2015 under ASIC class order 14/443.
