At the outset, Labor Senators express their disappointment that these
bills were introduced into Parliament on 14th September 2017, on a
Thursday morning on the last day of a two week sitting period. This was made
worse when very short reporting dates were set for not only these bills, but
also the Treasury Laws Amendment (Improving Accountability and Member Outcomes
in Superannuation Measures No. 2) Bill 2017 and Treasury Laws Amendment (Putting
Consumers First—Establishment of the Australian Financial Complaints Authority)
Labor Senators also note Senator Gallagher's request in the Senate to
extend the reporting date for the three superannuation bills given the
complexity of the reforms and note that this motion was voted down by the
Labor Senators are concerned that these bills, which claim to improve
governance in the superannuation sector, are being rushed through the committee
by this Government. What is worse, no clear explanation of the short reporting
date was even offered by the Government as a concession. As this report is
tabled, it will be three weeks before the first opportunity to debate this
legislation in the Senate. These three weeks could have been put to good use.
Labor Senators thank the Chair of the Committee for allowing two days of
hearings to cover the four bills mentioned previously. Labor Senators want to
thank Senator Hume and her office for being cooperative despite the
unreasonable timeframes set by the Government.
Labor Senators wish to make the following points about these two bills
and at the outset, want to say that Labor Senators reject both bills.
Superannuation Laws Amendment (Strengthening Trustee Arrangements) Bill
Labor Senators are proud of the Labor movement's history in establishing
the modern superannuation system.
Labor Senators are proud of Labor's record in helping to establish
industry funds (profit-to-member) – capital and labour at the same board
tables, working together to enable workers to have a decent retirement. Labor
has a proud record of bringing employers and employees, labour and capital,
together to take on challenges of the day.
Industry funds are an important element of Australia's financial system
and they offer alternative ways to run financial services firms. Industry
funds, according to analysis of APRA data by a number of stakeholders, have
outperformed retail and corporate superannuation funds on average. It appears
that industry funds have done a better job of making their 'customers' rich.
Financial services firms worldwide can be prone to making themselves wealthy at
the expense of customers, and is stated well in Fred Schwed's well-regarded
book titled 'Where are the Customers' Yachts?', first published in 1940.
Recent scandals in the banking sector in Australia underscore this problem.
This competitive tension between industry funds and their trustee
governance structure and other financial services firms with their corporate
governance structure is a good thing for the sector. Ideally, it should be a
race to the top to offer the best outcomes for working Australians.
Unfortunately, this government, by undermining industry funds, might be
promoting a race to the bottom.
Labor Senators note 2015 Senate Economics Legislation Committee report
into the predecessor of this bill, 'Superannuation Legislation Amendment
(Trustee Governance) Bill 2015' and the dissenting report by Labor Senators.
Many of the findings in this dissenting report are still relevant and Labor
Senators encourage people reading this report to consider the well-made
comments set out by Labor Senators in 2015.
Labor Senators hold the same primary concern with this bill, in that it
seeks to impose a corporate governance model on funds which operate under a
trustee governance model.
The primary difference with the 2017 bill is that is has been introduced
as a package with other superannuation bills to make the bill look more
Problems of corporate governance
that are mitigated by the presence of independent directors
Corporate governance faces particular issues which need to be addressed
Board members having a fiduciary duty only to their shareholder
owners, which can put at risk the needs of a company's customers; and
The presence of executive directors, that is, management of the
company having a presence on the board, where decisions might be taken that
advantage management over the needs of shareholders.
Labor Senators note that profit-to-member funds do not normally face
these same issues. As AIST note, profit-to-member funds do not face the
shareholder-customer conflict and also do not have executive directors on their
Prescribing independent directors does not take into account
the fact that layers of independence are entrenched within the profit-to-member
model, these layers are: independence from management, structural independence,
and independence safeguards derived from the broader regulatory framework.
The trustee governance model has different governance challenges
compared to corporate governance. Independent directors might be a suitable
policy for corporate governance risks, but they might not be the best policy
solution for trustee governance risks.
This legislation, like its predecessor, seeks to prescribe in law a
definition for independence.
The superannuation peak body, ASFA, raised concerns that this approach
could prevent a particular individual who could exercise independent judgement
from being a director. Instead, ASFA recommended a principles based approach be
ASFA went further and also stated that the ASX definition of
independence has worked well and there were no systemic issues found with its
I think Australian capital markets and the Australian
business community in general enjoy a reasonably high level of esteem
internationally, as reflected in the flow of funds that come into this country
as investment. Anecdotally, there is no evidence of systemic shortcomings in
corporate governance on the basis of that definition.
In proposing to mandate a minimum percentage of independent directors,
the Government expects that decision making on boards will be improved.
However, witnesses such as Jeremy Cooper and Graeme Samuel stated that
what should really be desired in board member selection is the concept of
'cognitive independence', that is, that each board member is able to think
independently of other board members, with diversity of thought leading to
better group decisions.
Let me say it this way: all of the legislative mechanisms you
are looking at will achieve what you might call structural independence, but
what you really want is cognitive independence. It's extremely difficult to
legislate for the second—it's almost accidental. You only learn that by talking
to someone and hearing their ideas and so on. But it's the cognitive
independence that you want.
...the view that I've always had as to 'independent directors'
is—I heard Jeremy Cooper just describe it then as the cognitive description of
'independence'—that I prefer to use the qualitative description.
It is clear from these observations that labels of 'independence' are
not the goal. Graeme Samuel made this point very clearly:
You can have as many so-called independent directors as you
like, but if the quality of the directors concerned—if their ability to
represent a dispassionate view, an objective view, and to have the courage of
their convictions—is non-existent, then the independent directors are
Mr Bernie Fraser made the observation that questions of independence are
secondary order issues for profit-to-member funds and that skills and values
should be the primary consideration:
The question of independence is peripheral, in my view,
compared with those skills and values. If you've got a board table that is
comprised, as most not-for-profit funds are, of directors who are committed,
who share the values of the members-first approach and who have the skills to
make the right decisions most of the time to handle the risks, that is the
critical thing. The question of how many of the directors who sit around a
board table happen to be independent is peripheral, in my view. It's not
germane to the task and the challenges facing all super funds. That's not to
say that there's a problem in independence as such—that's fine—but the
priorities are the skills and the values. If you can get those from members,
that's good. If you have to go outside the representative groups, the employers
and the unions, to get the skills—okay, some of those would be independent in
terms of the definitions of independence, but the critical thing is the skills
and the values.
The Corporate Superannuation Association also raised concerns about
arbitrarily imposing independent directors on some of their members:
The situation where members directly elect their own
representatives rather than relying on appointments by unions or other
representative bodies, has certain governance benefits arising from the
alignment of interests of members and trustee. We contend that where there is
immediate member accountability, the best interests of the members are
observed. In a fund that is not a public offer fund, we believe that member
interests are better served in this way than by statutorily imposed trustee directors
who have no connection with the workforce and no prior understanding of the
employment situation and the members.
This legislation also gives significant powers to APRA in deciding
whether a board has selected a director who is sufficiently 'independent'. By
giving this power to APRA, the Government has further blurred the lines of
accountability between ASIC and APRA in regulating corporate governance.
Given this blurring of responsibilities, Labor Senators echo the Shadow
Treasurer's comments that a banking Royal Commission should include in its work
a review of the regulatory roles of the RBA, ASIC and APRA in the financial
services and banking industries.
Independent directors and retail
Labor Senators are broadly supportive of the FSC's work in establishing
a standard for majority independent directors for corporate boards:
We have sought to move the industry towards a higher standard
of governance when introduced standard 20, our FSC superannuation governance
standard. This requires our member funds to appoint a majority of independent
directors and an independent chair, following on from the Cooper review of
superannuation. We believe that this sets the high-water mark for corporate
governance in the industry and meets the standards set by APRA for all the
financial services companies that it covers.
Labor Senators are also aware of examples where significant banking
entities have one governance structure for their retail fund and another for
their staff fund. For example, the Commonwealth Bank has a staff fund which has
an equal representation trustee model and a retail fund which has a majority
independent director model.
Labor Senators believe that the presence of independent directors hasn't
stopped scandals from emerging from some of the for-profit superannuation
funds. Industry Super Australia tabled a document claiming that $480m in
compensation, reimbursements, refunds, payments, remediation and consumer loss
for alleged misconduct between the big four banks, Macquarie and AMP.
This document also includes details of:
ANZ paying an additional $10.5m in compensation to 160,000
CBA paying $16.3m to staff after a review of superannuation
NAB's superannuation trustee company paying $35m in compensation
for two breaches involving failures in relation to provision of general advice;
Westpac's BT Financial Group paying $12 million to customers
whose life insurance claims were knocked back.
Labor Senators believe that independent directors are no silver bullet
to problems in the financial services and banking industries.
The FSC claimed that the presence of independent directors would help
with the merging of underperforming default funds:
For example, as detailed in our submission, a major issue
facing the industry has been the ongoing resistance of subscale and inefficient
funds to resist merging with larger and more efficient funds. This is a major
drag on returns for consumers. Our analysis has shown that the average consumer
defaulted into a subscale fund as a result of the modern award system and may
be as much as $170,000 worse off by retirement. There are 1.7 million consumer
accounts containing $94 billion currently languishing in the 33 subscale funds
in the award system.
The argument made is that independent directors would act in the
interests of members when non-independent directors might be 'conflicted by
their relationship to a sponsoring organisation that may want to continue the
fund as a going concern'.
Industry Super Australia refuted this claim and stated that:
Independent directors are no panacea to merger activity. Many
independent directors, if they're professional independent directors, owe their
likelihood to their directorships. If they're in a situation where a board is
merging and their board position no longer is in existence, then they stand to
lose financially as a consequence of that. I think it's well worthwhile looking
at the detail in the APRA statistics to see the prevalence of small retail
funds, which—despite the apparent prevalence of independent directors—are not
consolidating at the rate that probably everyone would expect to see.
Removal of requirement for equal
The bill not only mandates a minimum one-third independent directors,
but also goes further by removing the requirement for equal representation. As
stated by AIST:
The removal of equal representation from the SIS act is
equally concerning to us. The equal representation model of governance has been
the cornerstone of member representation and accountability in the
superannuation industry for decades.
Consumer representative group Choice also shared concerns about possible
outcomes of this bill in their submission:
The Bill has the potential to destroy the unique value and
culture brought by member directors. Our review of the available evidence
suggests that member directors, where appropriately selected, can contribute to
good governance, so a role for them should be retained.
Choice went further in testimony adding:
We're particularly concerned, given our role as a consumer
organisation, about the loss of member representation. This is consistent with
our position over time. We've long maintained and supported member
participation in the governance of super boards.
The Australian Council of Trade Unions stated that this measure would be
a significant step backwards on fund governance:
You ask the question: is it possible for an organisation to
basically hold the other two-thirds of the shares? That is correct. That could
happen under the bill. And, if that was the case, then clearly you would have a
situation where there was effective control over a company, and the model which
I say we have eschewed for 30 years would be the model which took place for a
default superannuation arrangement. We think that is inappropriate.
Labor Senators believe that this move away from the concept of equal
representation is an unwarranted step that could have significant adverse
outcomes for members.
Profit-to-member funds have not been idle when reviewing their own
governance arrangements. Two pieces of significant work have been carried out
in parallel with each other.
The first is the AIST governance code that will be mandatory for members
next year. As stated by AIST in testimony:
In recognition of this and our commitment to a culture of
continuous improvement in governance practices, AIST this year launched a
governance code that will be mandatory for more than 50 AIST member funds from
1 July 2018. This builds on a voluntary set of guidelines that we published
first in 2011. The code and accompanying guidance are designed to firmly
position profit-to-member super funds at the leading edge of international best
practice. The code was developed separately but in tandem with the Fraser
review and follows a commitment made by AIST and Industry Super Australia to
the Australian Senate at the end of 2015. The code mirrors ASX corporate
governance principles, applying them obviously in the superannuation context,
to reflect an industry that is structured and regulated differently to listed
companies. The principles-based code contains 21 requirements that funds must
report against annually on an 'if not, why not' basis. These requirements cover
member engagement opportunities, equal director voting rights, strong risk
culture, board renewal, chair appointment, disclosure, transparency, diversity
and remuneration. Member compliance with the code will be monitored by an
independent body which can make recommendations to AIST on areas where further
guidance may be warranted.
The second undertaking was the Fraser review, commissioned after the
2015 bill was not passed by the Senate. Mr Fraser was unequivocal in his view
that the governance challenges for profit-to-member boards would be in finding
people with the right skills and values:
There's always scope to improve things, and these are dynamic
things. Funds have been improving. The governance of all funds has been
changing and improving over time, and this will continue to be a requirement.
But what has really underlined the better performance and the better behaviour
of the not-for-profit funds, as I say, has been their values and their skills.
They're the critical things that are going to be important in determining the future
performance of funds. That's going to be a very challenging circumstance.
Investment risks and other risks, as you all know, are increasing. They're on
the rise for all kinds of reasons: globalisation, technological changes and
geopolitical developments of all kinds. It's going to be more and more
challenging to maintain the values. More importantly, maintaining the values in
the not-for-profit funds is pretty clear because there are no real conflicts
with other parties and other interests. Maintaining the skills and developing
the right skill mix—and these are going to be all sorts of skills:
technological skills and geopolitical skills, not just financial skills, which
have been the focus in the past. Getting those skills and keeping them is going
to be a challenge for all funds, including the not-for-profit funds.
Labor Senators note the work by profit-to-member funds in improving
their governance arrangements and welcome the introduction of the AIST
The justification for the requirement
of independent directors
Several assertions were made to justify the introduction of this bill.
Two notable arguments were made at the hearing by Mr Murray AO:
Firstly, we had picked up a model in which employee
representatives and employer representatives were present from the defined
Next, the governance system is inconsistent with public offer
rules under the corporations law and for managed investment schemes.
In neither case was the argument made that there was a problem with existing
governance arrangements in profit-to-member funds. In fact, the balance of
evidence suggests, that on average, profit-to-member funds outperform their
Regarding the first argument of equal representation and the defined
benefit system, it should be noted that Denmark and the Netherlands require
equal representation, and are ranked as the top two retirement income systems
by the Melbourne-Mercer Global Pensions Index.
Mr Cooper gave evidence to suggest that the Netherlands were moving away
from strict equal representation:
Leading pension systems are actually moving away from the
strict equal representation model and are putting independent directors on
their pension schemes—most notably—and, I suppose, of most relevance for
Australia, the Netherlands, which is seen as being in the elite top two of
In questions on notice to this committee, Industry Super Australia
responded, saying that the move by the Netherlands towards independent
directors was a voluntary suggestion that boards could adopt if they believed
that it was in the interests of their members:
In 2014 the Dutch Labour Foundation (a joint union-employer
body), in collaboration with the Federation of the Dutch Pension Funds,
published a new ‘Code of the Dutch Pension Funds.
This Code contained suggestions for how Dutch pension funds
could model their governance arrangements. These suggestions included giving
consideration to appointing 1 or 2 external/independent members to a board if a
fund believed such appointments would be in the best interests of members.
The Code is principles-based and does not prescribe
appointing external members. Funds can adopt some, all or none of the Code
depending on their particular circumstances. Where funds have complying equal
representation arrangements, they are free to continue with those arrangements
if they believe them to be in the best interests of members.
Regarding the second argument of rules in other laws, it does not seem
clear that rules under corporations law and for managed investment schemes
should automatically inform governance structures in the superannuation
industry, particularly when there is no identified problem to solve.
Academics have also stated findings in their research raising doubts
about the link between the presence of independent directors and fund
performance. In particular, Dr Kevin Liu found that:
There is insufficient empirical evidence supporting a
(statistically and economically) significant relationship between a higher
number (and proportion) of 'independent directors' and better fund performance.
Dr Scott Donald also found that:
Research I conducted with Associate Professor Suzanne Le Mire
in 2015 found little empirical evidence that structural independence measures
such as those envisaged in the Independence Bill are associated with higher
investment returns or lower risk, the usual metrics of performance in the
superannuation and pensions domain globally.
Given the evidence received by this committee, Labor Senators believe
that there is insufficient evidence to establish that a problem exists in
Australian superannuation governance that warrants legislative change and that
the presence of a proportion of independent directors can be linked to improved
fund returns. The justification for this legislation is very weak.
Labor Senators' position on this
Labor Senators believe that no clear evidence has been offered to
demonstrate why these changes are necessary. A Government which purports to be
conservative, non-interventionist and pro-market would be expected to introduce
additional regulation only where there is evidence of clear market failure.
This bill would disproportionately impact profit-to-member funds when
evidence suggests it is the retail and banking sectors which need Government
Labor Senators are not opposed to independent directors as a principle.
Where trustee boards believe that independent directors would enhance board
decision making they should be appointed. Many profit-to-member funds have
adopted such appointments. However, Labor Senators do not believe in
prescribing an arbitrary quota of independent directors and defining
independence in legislation. Labor Senators welcome the work of AIST in
developing a governance code and endorse the idea that 'cognitive independence'
is what policy makers should strive to achieve.
Labor Senators also have a preference to focus on 'outcomes' in
superannuation (for example, net returns to members), rather than 'inputs' such
as the number of independent directors. An outcomes approach enables different
funds to pursue different business models in the pursuit of outcomes such as
net returns to members.
Labor Senators remained concerned that the primary intent of this bill
might not be related to policy matters.
To oppose the Superannuation Laws Amendment (Strengthening
Trustee Arrangements) Bill 2017
Treasury Laws Amendment (Improving Accountability and Member Outcomes in
Superannuation Measures No. 1) Bill 2017
As set out in the Explanatory Memorandum – this bill has a number of
schedules and is a dense piece of legislation. Before commenting on specific
schedules, Labor Senators would like to express a number of high level
Labor Senators are concerned that this legislation will not improve
protections, accountability and outcomes for all members across the sector.
In particular, the need to strengthen outcomes for Choice products and
to improve the reporting and accountability of retail RSEs with a large
financial firm parent company have not been given due consideration in this
The need for stronger protections
for both MySuper and Choice products
Mr Cooper agreed with the assertion that his notable recommendation for
the establishment of a MySuper product would act as a well performing default
product. Choice products would have to compete against this high bar.
Senator KETTER: Let me just ask you: would you envisage
MySuper being a strong default product with the view of setting a high bar for
competition, and that choice products need to compete against this MySuper high
bar by offering stronger net returns to get people to switch?
Mr Cooper: Yes, I would.
The assumption in this thinking is that people have full information and
are able to use that information to act in their own best interests –
evaluating the returns on their default product, finding a choice product that
offered some combination of stronger net returns and other benefits and then
making the switch.
However, a recent Rice Warner report commissioned by Industry Super
Australia finds that the evidence suggests that this is not what is occurring
in practice. It would appear that people are increasingly switching to products
that are more costly and have poorer returns.
The Rice Warner report notes that:
Members are unlikely to have used fee levels as a primary
reason for switching between funds, as many members are charged a higher fee
after switching... The aggregate fee outcomes from switching activity reveals a
net increase of $137 million in fees.
Members are unlikely to have used past performance as a proxy
for their investment decision as the data shows on average that historical
returns for the incumbent and successor fund tend to be similar.
36% of members would have received higher returns over the
period, while 56% of members would have received lower returns. 8% of members
did not see a notable increase or decrease in investment performance (with a
margin of 0.05% either way).
The aggregate estimated impact on investment returns reveals
a net decrease of $284 million annually. This ls largely driven by a $373
million decrease in returns annually for members rolling into funds with lower
returns. Retail funds accounted for 87% of this decrease in returns.
These findings raise significant questions about the ability of
consumers to effectively compare across superannuation products.
Given the findings that many members are switching to lower performing
products, Labor Senators believe that there needs to be stronger protections
for both MySuper and Choice products.
This view is also endorsed by the Financial Services Council:
The FSC supports higher standards of governance, transparency
and accountability for both choice and MySuper products.
Retail fund performance
Objections are often made when the claim that industry funds outperform
retail funds, citing asset allocation and a difference in member demographics:
And the result of that is that the returns will inherently be
lower because you have more in cash, more in bonds and less in growth assets.
ISA will say, 'Therefore, you're a badly-performing fund.' But if I were a
75-year-old and I had a high-risk asset allocation, and we had something like
the global financial crisis and I lost 30 or 40 per cent of my investments then
I wouldn't have thanked the trustees in their decision. In fact, I would be
wishing that there were independent directors on the board saying that it was
more important to make the right investment decisions for my circumstances than
it was necessary to top the league tables so they could defend our brand.
It's not just the governance structure; it's the underlying
assets and investment strategy and the composition; it's the demographics; and
it's the range of products. You've got a number of different features that are
within any RSE. So comparing at fund level, and particularly comparing averages
by sector, is just not meaningful.
Both AIST and ISA offered criticisms of those claims––citing that their
two percentage point performance advantage
over retail funds could not be fully explained by these issues.
Industry Super Australia in response to Questions on Notice cited
evidence to show that the difference between Industry fund and Retail fund cash
options (simple asset, easy to compare) still had a difference in returns of
0.8 per cent to 1.5 per cent.
In testimony to the committee, AIST noted that:
Research that AIST commissioned earlier this year showed that
the choice sector underperformed generally across like-for-like asset
allocations compared to MySuper asset allocations and that fee structures were
between 53 and 280 per cent more expensive in the choice sector. So we are
concerned that this remains. In addition to that, all retiree money is in the
choice sector. That is another very important reason that that be captured.
That's our basic view in relation to choice.
Labor Senators also note that Treasury have not undertaken work
themselves to understand these claims:
Senator KETTER: Thank you. Has Treasury done any analysis on
what's driving the difference in performance in terms of net returns between
the different types of super funds?
Mr Beckett: We haven't done any analysis ourselves.
Labor Senators remain concerned that issues of asset allocation and
member demographics do not completely explain the gap in average fund
Labor Senators would also encourage Treasury officials to use publically
available APRA data to explore these issues and report to the committee on its
Comments on the schedules in this
Schedule 1 - Annual MySuper
Labor Senators welcome the introduction of an outcomes test to replace
the scale test.
Labor Senators note ISA's analysis that indicates that the benefits of
scale are not accruing to members of all funds.
Figure 1 indicates that there are large funds operated by Westpac, ANZ, CBA,
AMP and NAB which are clustered around the bottom quartile of performance. As
scale remains as one factor in the outcomes test, this issue should be
ISA in their submission also noted that an outcomes test should also
place as primary important the outcome of net returns to members.
Concerns were also raised that the MySuper outcomes test would be
prescribed in legislation, whereas APRA has only committed so far to consulting
on proposed changes to prudential standards to include an outcomes test for
Labor Senators believe that an outcomes test should apply to all
products, not just MySuper products.
Schedule 2 - Authority to offer a
Labor Senators note concerns that APRA's proposed authority is different
to its authority to refuse an RSE license, giving the appearance that there are
different protections for those with MySuper products compared to Choice
Schedule 3 - Director penalties
Labor Senators note concerns from stakeholders about:
Whether penalties should be extended to directors of
superannuation funds that offer Choice products
The proposal exposed superannuation trustees directors to greater
risk of personal liability than other company directors
Whether a set of protections, such as good faith actions, should
The interaction of the directions power with these penalties
Schedule 5 - APRA directions power
Labor Senators note concerns raised by a variety of stakeholder that
APRA’s proposed powers are too broad. As ASFA stated in their submission:
In particular we question the breadth of the proposed APRA
directions powers and whether they could be more precise
AIST also raised concerns that the directions power does not adequately
consider the corporate structures of the retail fund sector:
While we support the expansion of the directions power to
cover connected entities, the current provision is fundamentally flawed because
it does not have consistent application across sectors of the superannuation
industry –notably, superannuation funds operating in a retail environment would
attract less scrutiny.
Schedule 6 - Portfolio holdings
ISA raised the concern that 'this Bill seeks to amend the current
requirements so that the disclosure requirement does not apply to choice
products that contain multiple investment options (an intrinsic feature of
Treasury officials responded to this concern by stating 'I would like to
make a very brief opening statement simply to confirm that there is no platform
carve-out in the portfolio holdings disclosure provisions'.
Labor Senators note the Treasury's advice that the portfolio holdings
disclosure requirements in this Bill will cover platform products.
Schedule 7 - Annual Member’s
Labor Senators note the number of submissions that raised concerns about
the prescriptive nature of the requirements of an Annual Member’s Meeting and
whether the cost of running these meetings would be outweighed by the benefits of
practical member engagement.
Schedule 8 - Reporting standards
Labor Senators endorse the concept of improving transparency to members.
Labor Senators note that some funds are currently reporting zero
investment fees and expenses under current reporting standards.
Labor Senators call on the Government to fix the current reporting
regime before introducing new reporting requirements.
Labor Senators call on the Government to end the five year deferral on
the rollout of choice product dashboards.
Labor Senators' position on this
Labor Senators believe that there needs to be proper protections for
both MySuper and Choice products. Given the findings in the Rice Warner report,
it is likely that customers are not being provided easy access to sufficient information
so as to enable ready comparison of products.
Labor Senators believe that this bill fails to sufficiently strengthen
protections and outcomes for choice products and to sufficiently increase
scrutiny of retail funds.
When considered alongside the trustee arrangements bill, Labor Senators
are concerned that the primary intent of this bill might not be related to
To oppose the Treasury Laws Amendment (Improving Accountability
and Member Outcomes in Superannuation Measures No. 1) Bill 2017 unless the bill
applies consistently and comprehensively across the superannuation system.
Senator Chris Ketter Senator
Deputy Chair Senator
for New South Wales
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