Retirement Income Disclosure Consultation Paper
The submission to The Treasury in relation to its Retirement Income Disclosure Consultation Paper was prepared by the Superannuation Committee of the Legal Practice Section.
The Consultation Paper proposes that a Retirement Income (product) Disclosure Fact Sheet (RID Fact Sheet) be introduced incorporating key information and prescribed metrics which would operate (and be provided to members and prospective members) as a separate disclosure requirement to existing Product Disclosure Statement (PDS) requirements. Instead, in the context above, we submit consideration should be given to making the core RID Fact Sheet proposed operate as part of the PDS disclosure required rather than in addition to it.
To this end, we suggest mandating a modified, short-form PDS disclosure regime for CIPRs which would include as part of a CIPR PDS, provision of the product’s RID Fact Sheet. This submission does not seek to respond to issues of policy. As the consultation paper largely seeks input on the proposed metrics for the prescribed disclosure, requiring technical actuarial or investment risk expertise, our observations are otherwise limited to matters of clarity. Our observations are all intended to relate to the Committee’s objective of ensuring that the law relating to superannuation in Australia is sound, equitable and demonstrably clear and, in the context of these proposals, that prescribed product disclosure is likely to be effective for its intended purpose.
You can read the full submission below.