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Improved superannuation transparency consultation

The Law Council welcomes the opportunity to provide comments on the consultation package “Improved Superannuation Transparency”. 

With regard to the proposed product dashboard reforms: 

• Most funds will likely require a longer transition period – for example, 12 months from when the requirements are finalised. 

• Clarification is required as to whether funds only need to prepare a maximum of 10 dashboards (plus a MySuper dashboard, if applicable), or 10 dashboards for each sub-plan within the fund. 

• If it is intended for 10 dashboards to be prepared for each sub-plan, funds should be permitted to aggregate (or use a shared dashboard) for investment options offered within the same fund which are substantially identical for practical purposes. 

• We are troubled by the proposed prohibition against including non-mandatory information in the dashboard. Given the concerns that certain types of data proposed to be included in dashboards could be misleading and deceptive, funds should be permitted to include clarifying information in their dashboards to ensure that their members are not misled. 

• We reiterate previously expressed concerns regarding particular components of the dashboard – for example, return target, the standard risk classifications (which focus on frequency of negative returns while ignoring the magnitude of those negative returns) and the focus on net returns as opposed to net investment returns. 

• Compelling funds to publish a return target defined by reference to inflation is problematic for options that do not in actual fact target returns which exceed inflation. 

• If strategic asset allocation information is to be included, it is important for the associated tolerance ranges to be included. 

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