Frequently Asked Questions - Superannuation Data Transformation

Yes, RSE licensees must report all investments options in SRF 550.0 table 2 (excluding those that are permitted to be excluded under the reporting standard). APRA introduced 'Not available' as a permissible value for detailed asset class characteristics 1, 2 and 3 in specific circumstances outlined under the reporting standard, including where investments are held via a non-connected investment vehicle.

However, APRA expects RSE licensees to know, and to be able to report, actual sector information (in columns 6, 10, 11 & 12) at a minimum. Where data as at the quarter end is not available at the due date, RSE licensees are to use the best data available as at the reporting date in specific circumstances outlined under the reporting standard, including where investments are held via a non-connected investment vehicle.

Where entities report using best available information at the reporting date, and better information becomes available, entities should consider whether there is a material difference to the reported values. If so, APRA expects RSE licensees to resubmit in this following period. APRA expects RSE licensees to define materiality in their internal governance procedures, having consideration of use of the data and whether that difference it would impact the users’ interpretation or decision based on that data. 

This does not override APRA’s expectation that any material errors identified in any previous reporting should be notified to APRA and resubmission requested as per the normal processes.

Multiple changes in a period that relate to different rows are catered to by entering the relevant data of change for each row. Date of change must be filled in where the status is ‘changed’. 

Multiple changes in a period that relate to the same row of data will require separate ad hoc submissions using the relevant “Date of Change” in each submission. 

No. Entities will be required to submit 30 June data for SRF 550.1 and SRF 706.0 in accordance with the due date under SRS 550.0 and SRS 706.0.

If the RSE licensee identifies that any material changes to the 30 June data are required following outcomes of the audit process, then APRA expects entities to resubmit the relevant data. 

APRA expects that RSE licensees will complete SRS 605.0 RSE Structure, SRS 332.0 Expenses and SRS 550.0 Asset Allocation in respect of any PSTs under their trusteeship.

For each table in SRS 605.0 RSE Structure, an RSE licensee can report a PST as a single row in each table, however where relevant the RSE licensee should report a different investment option for each separately identifiable pool of assets that are within the PST.

RSE licensees must provide APRA with an attestation at the end of each calendar quarter to confirm that there has been no change to the latest information provided for reporting forms SRF 251.3, SRF 605.0 and SRF 706.0 that would require an ad-hoc submission.

Yes, SRS 605.0 RSE Structure (SRS 605.0) return should be submitted before attempting to upload and submit all returns except data under SRS 332.0 Expenses (SRS 332.0). RSE Structure defines:

• Superannuation products
• Investment menus
• Investment options
• Fees and costs arrangements

This sets up each of the entity’s business operations in APRA's system so that they can lodge a range of regulatory returns.

SRS 605.0 needs to be submitted and up-to-date before submitting the returns under:

• SRS 251.0 Insurance Arrangements (SRS 251.0)
• SRS 550.0 Asset Allocation (SRS 550.0)
• SRS 606.0 RSE Profile (SRS 606.0)
• SRS 611.0 Member Accounts (SRS 611.0)
• Attestation 

SRS 605.0 and SRS 606.0 both need to be submitted and up-to-date before submitting the returns under:

• SRS 705.0 Performance Components (SRS 705.0)
• SRS 705.1 Performance Benchmark (SRS 705.1)
• SRS 706.0 Fees and Costs (SRS 706.0)

Where an RSE licensee is unable to source the required information for externally managed investment options for reporting on investment performance for historical periods and investment objectives and investment objective performance under SRS 705.1 for each quarter by the due date, report the best available data. Where the RSE licensee does not have best available data an RSE licensee may report 999. Where the data becomes available, APRA expects the RSE licensee to update the submission. 

APRA expects RSE licensees to have access to investment data that enables a RSE licensee: 

• to meet its obligations in Prudential Standard SPS 530 Investment Governance (SPS 530);  
   
• to act in the best financial interests of beneficiaries;  
   
• prudently select, manage and monitor investments on behalf of beneficiaries; and  
   
• to implement a sound investment governance framework that focuses on managing relevant risks and returns. 

This obligation in SPS 530 applies to all investment options including externally managed investment options.

APRA has published a new set of frequently asked questions (FAQs) to provide clarity to RSE licensees on the introduction of trustee directed products (TDPs) into the Government’s Your Future, Your Super performance test: Your Future, Your Super Frequently Asked Questions.

For an ad-hoc submission of SRF 251.3 and SRF 706.0, an RSE licensee should report data for the entire reporting form, including data that has not changed. 

For an ad-hoc submission of SRF 605.0 an RSE licensee is only able to report the data that is new or has changed. The status in column 1 of each table in SRF 605.0 will enable the system to determine whether a row contains new, updated or unchanged data. The whole table can be left blank if all the data is unchanged.

RSE licensees should request a resubmission of forms through APRA Connect. Please refer to section 7.3 of the APRA Connect Guide for instructions on how to request a resubmission. 

With the exception of SRS 605.0 RSE Structure, any requests for a resubmission prior to the due date, or up to 15 days after the due date, will automatically be approved. Requests for resubmission of SRS 605.0 RSE Structure will be assessed and approved manually.

To correct or amend data in SRS 605.0 RSE Structure, an RSE licensee should report an ad-hoc submission by clicking the Create Return button on the Manage Returns page and selecting SRS 605.0 RSE Structure from the Select form set box. The RSE licensee is able to submit only the data that is new or has changed. Any records that have already been registered in the Corporate Profile will trigger validation rules – preventing submission, if the status is New. 

RSE licensees should be aware that there is only functionality in APRA Connect for changes to items but not the removal of items in a resubmission or ad-hoc submission. If a structural reporting error has been made on SRS 605.0, please contact APRA at dataanalytics@apra.gov.au.

Table 1 of  SRF 251.0 collects information for each group policy held by the RSE as well as individual policies made for individual members. RSE licensees can collate reporting of individual policies that have a common insurer together as a cluster. Please report the number of policies included in the cluster (this would be ‘1’ for group policies). 

It would depend if the member is under the same policy or not. For example, if a member is covered under a group policy but requires additional underwriting to obtain cover, APRA would not expect this to be reported as a separate policy.

If a member requires additional underwriting and ultimately ends up with a new individual policy, this would need to be reported as an individual policy (or as part of a cluster of individual policies).

APRA has listed six occupation categories to describe the type of occupation covered by the policy. RSE licensees should select ‘Yes’ for one or more occupation categories that would be covered under the RSE's occupation definition.

APRA expects that the premiums paid and the claims history for these members would be available to the receiving trustee in order to administer the insurance arrangements. Accordingly, it should be reported by the receiving trustee in the historical data for SRS 251.0.

Not necessarily. The default cover offered indicator relates to the type of cover, not the level of cover. If a member automatically obtained the current type of insurance (for example, upon joining the fund), then the RSE licensee should report ‘Yes’, regardless of whether the member has since increased or decreased the level of cover. See the definition of default cover offered in SRS 101.0 for further detail.

Yes, these members are considered as having default cover offered to them.  For further information, please refer to the definition of ‘Default cover offered’ in Reporting Standard SRS 101.0 0 Definitions for Superannuation Data Collections (see SRS 101.0 under Phase 1 Consultation, Reporting Standards).

APRA expects RSE licensees to report new business or ceased member accounts for any insurance cluster in SRF 251.1 table 1.  

Where a member retains the same insurance cover under a policy, but switches to a different superannuation product, RSE licensees should not include that member in the count for column 6, new Business Member Accounts or column 7, Ceased Member Accounts, as the insurance cover of the member is unchanged. In some cases, this will mean that for a reported row of a combination of product and insurance cluster, Beginning Period Member Accounts plus New Business Member Accounts less Ceased Member Accounts will not reconcile to End Period Member Accounts. For each cluster, and for the table as a whole, APRA expects that these columns will reconcile. 

APRA expects RSE licensees to report claims payment data for SRF 251.2 reflecting when the member has been paid.  

APRA expects RSE licensees to report claim amounts in column 5 'Insurance claim paid amount'. RSE licensees should exclude amounts paid from other sources such as the member balance.

Where the assessment criteria is not readily available:

• APRA’s preference is for RSE licensees to estimate the number of TPD claims by assessment criteria (e.g. based on experience where data is available). In doing so, APRA expects RSE licensees to:

o    provide the estimates under each category of 'Assessment Criteria Total And Permanent Disability Type' for the relevant periods; and

o    provide their methodology of estimation in the free text box provided in ‘Assessment Criteria Other Total And Permanent Disability Description Text’ (column 3, table 5 of SRF 251.2). 

•  If an estimation is not possible, please select ‘Other’ for ‘Assessment Criteria Total And Permanent Disability Type’ and explain why an estimation is not possible in the free text box in the next column in ‘Assessment Criteria Other Total And Permanent Disability Description Text’ (column 3, table 5 of SRF 251.2).

APRA expects that RSE licensees will report withdrawn insurance claims under column 6 of SRF 251.2 table 4 'Insurance Claim Withdrawn Count'. 

APRA expects that RSE licensees will not report withdrawn insurance claims under SRF 251.2 table 5 and that ‘withdrawal’ is not a valid value in column 6 of SRF 251.2 table 5.

RSE licensees can report insurance claims that have been closed under SRF 251.2 table 5, providing that the insurance claim has also been reported under column 9 of SRF 251.2 table 4. For example, an RSE Licensee can report an insurance claim under SRF 251.2 table 5 that has been closed due to lack of communication where the insurance claim has also been reported under column 9 of SRF 251.2 table 4. 

Where an RSE licensee re-opens an insurance claim, APRA expects RSE licensees to report the claim as reopened on SRF 251.2 table 4 column 5.

Where the reopened claim was admitted during the reporting period, APRA expects RSE licensees to include the duration of the reopened claims when calculating the Insurance Average Claim Duration Number (SRF 251.2 table 2 column 6) from the date that the insurance claim was reopened, in addition to the duration of the claim from the date that the claim was received to the date the claim was declined initially.

Where the reopened claim is undetermined at the end of the reporting period, APRA expects RSE licensees to include the duration of the reopened claims which remain undetermined when calculating the Insurance Claim Average Undetermined Duration Number (SRF 251.2 table 4 column 11) from the date that the insurance claim was reopened, in addition to the duration of the claim from the date that the claim was received to the date the claim was declined initially.
 

No, age-bands cannot be reported. For table 2 column 3 on SRF 251.3 the individual age of members (as at last birthday) is to be reported. 

Yes, all insurance offerings that are either partially or fully funded by the members’ employer should be included in the amount reported for ‘Insurance Cover Cost Amount’.

In line with the reporting of premiums in SRF 251.2 Insurance payments table 1, APRA expects RSE licensees to report each Insurance Cover Type required in SRF 251.3 table 1 as a separate row so as to apportion the Insurance Cover Cost Amount for each of the insurance cover types in the bundled cover. 

For reporting under SRF 251.3, APRA expects RSE licensees to report each insurance cluster where the default indicator in SRF 251.1 table 1 is reported as ‘Yes’. This includes all group policies, noting that there is no materiality threshold.  

APRA expects that where different premium rates apply to different employer groups, these should be reported as separate rows with a different Insurance Table Identifier for table 1. The same approach should also be adopted for table 2. 

If premium rates are the same for multiple employer groups, then these should be reported as a single row in table 1 of SRF 251.3. 

APRA expects RSE licensees to incorporate variable factors into column 9, ‘Insurance Cover Default Cover Level Salary Percent’ for SRF 251.3 table 2.

If cover incorporates future service, calculate a factor using the assumed retirement age or cover ceasing age as per the benefit design and the member age reported in each row.

If cover incorporates past service, calculate a factor using a representative member who joined the fund/plan at the cover entry age and the member age reported in each row.

For example, where default cover is calculated as future years of service X 15 per cent of salary, for a 30 year old member the future years of service factor would be 35 (65 – 30), and the RSE licensee would report 5.25 in column 9 (35 X 15 per cent).

Where the default level of cover has been expressed as a percentage of salary, RSE licensees should report the annual cost of cover per $1,000 of cover in column 10 ‘Insurance Cover Cost Amount’. 
 

SRF 251.3 collects information on insurance premiums disclosed to members on a forward-looking basis. 

APRA expects that tax rebates from insurance premiums as disclosed to members should be reported in SRF 251.3 table 2 column 11 where they apply to all members under the relevant insurance policy. 

Rebates that are dependent on member activity, such as reductions to contributions tax should not be reported under SRF 251.3 table 2 column 11. 

APRA expects RSE licensees to report the ‘Insurance Cover Cost’ amount for Income Protection Insurance Cover as the annual cost per $1000 of monthly insured benefit where the default level of cover has been expressed as a percentage of salary. 

For Life Insurance Cover and Total and Permanent Disability Insurance Cover the ‘Insurance Cover Cost’ should be reported as the annual cost per $1000 of insurance cover where the default level of cover has been expressed as a percentage of salary.  

APRA expects that the cost of cover is reported to four decimal places as this will ensure that publication of insurance costs is accurate and comparable. In particular, where insurance cover amount is reported as a percentage of salary and the cost of cover reported is based on the annual cost of $1,000 of cover, please report the cost to four decimal places to ensure sufficient precision to enable accurate and comparable cost of cover. 

A one-off Service Arrangement Engagement Type is when there is a discrete piece of work that the service provider has been engaged to complete. An example may include an engagement for legal advice on a specific issue, a one-off IT build, or consulting costs for engagement of specialist advisers on a discrete project. A one-off engagement may continue over one or more reporting periods.

An ongoing Service Arrangement Engagement Type is when there is a continuous arrangement for the ongoing provision of services. For example, ongoing administration services, ongoing software or IT support or ongoing investment management services.

Where the RSE licensees cannot report accruals against specific service provider, APRA expects payments in the reporting period to be reported against the most relevant service provider. Accrual adjustments can be reported against the service provider labelled ‘Accounting concepts’ as per FAQ 332.0c, and classified under the relevant expense group type and expense type. In subsequent reporting periods, if a reversal of an accrual adjustment is required, the reversal should be made against the same ‘Accounting concepts’ line the accrual was mapped to initially.

RSE licensees should report the total expense amount in respect of each expense type captured under the relevant service agreement. Where the expense for each service is not specified in the relevant service agreement, the expense amount should be apportioned across the expense categories for which the trustee fee is used.

If payments are made to a connected entity, report the expense with the last connected entity in the look-through chain, please see the worked example. 

The intent of SRS 332.0 is to understand how RSE licensees are spending members’ money, and with whom.  Please refer to the SRS 332.0 Expenses Worked Example cover sheet for the look-through diagram and relevant examples.

In classifying expenses on an APRA look-through basis, RSE licensees should classify items based on the purpose for which the RSE licensee spent the money.

Where the service arrangement covers more than one expense type, RSE licensees should apportion the total expense amount between each expense type.

For example, where an RSE licensee has paid an external administrator, the RSE licensee should not report the corporate overheads of the external administrator. This expense should be categorised under each of the relevant administration expense type for which a service is provided.

APRA proposes to clarify the definition of Marketing in SRS 101.0 to capture internal marketing expenses by including the following clarification:

"Where the service provider is the RSE Licensee, means any other expense incurred for the purpose of promotion or marketing".

Expenses should be classified as a ‘related party expense’ in Table 2 and Table 3 in line with the definition of related party for the purposes of accounting standard AASB 124 Related Party Disclosures and/or a Related Party as defined in subsection 10(1) of the SIS Act.

Where a service provider or payee is only a related party of the RSE licensee due to a standard employer sponsor relationship or on the sole basis of that person being a member of the fund, and the relationship with that entity does not result in a relevant duty or relevant interest under Prudential Standard SPS 521 Conflicts of Interest, no relationship is required to be reported in ‘Service provider relationship type’ in Table 1 and Table 4 of SRS 332.0. 

Entities can report a row for the same service provider / payee and expense type which varies by ‘Expense Group Type’ in Table 2 – Administration and other expenses reporting; and can report a row for ‘Administration and other expenses’ and for ‘Investment Management expenses’ for the same service provider / payee in Table 4 – Related Party Reporting. APRA intends to clarify Reporting Standard SRS 332.0 Expenses to reflect these expectations.

APRA expects that payroll tax is reported as part of the wage or remuneration expense associated with the relevant ‘Expense group type’, ‘Expense type’, ‘Service arrangement inclusions exclusions text’ and ‘Service arrangement engagement type’. For example, payroll tax associated with staff wages for in-house marketing staff working on member campaigns might be reported as expense group type ‘Marketing’, expense type ‘Member campaigns’ and service arrangement engagement type 'Staff wages’, with the RSE Licensee as the payee.

APRA expects the total of director and executive remuneration reported in SRS 332.0 for each RSE under a RSE licensee to be consistent with the disclosed remuneration reported with the RSE licensee financial statements.

Where director remuneration is paid to an industrial body, the service provider type should be reported as ‘Industrial Body’ in table 1, with the following corresponding classifications to be reported in table 2; expense group type ‘Trustee Board’, expense type ‘Board and Board Committees’ and the service arrangement engagement type ‘Director Remuneration’. 

When reporting director remuneration paid to an individual, it is to be reported under the expense group type ‘Trustee Board’, the expense type ‘Board and Board Committees’ and the service arrangement engagement type reported as ‘Director Remuneration’, with the RSE licensee as the service provider. 

APRA expects that, as a general principle, there is alignment of total expenses reported under SRS 332.0 to the total expenses on the RSE financial statements.

If a payment was made on behalf of the entity where a purpose of each payment was promoting the entity, promoting a particular view on behalf of the entity or sponsorship on behalf of the entity but that payment does not form part of the expenses of the fund, the RSE licensee may report the amount of the payment made by or on behalf of the entity as an expense in Table 2; and on a separate row report a negative of the amount paid on behalf of the entity to net out this figure to the actual expense of the entity.

These expenses should be reported with the same Expense Group Type and Expense Type and Service Arrangement Engagement Type, with a description in the Service Arrangement Inclusions Exclusions Text explaining the reported items are ‘$x of payment made on behalf of the RSE’ and ‘reflecting payment made on behalf of the RSE and is not part of RSE expenses’.

The intent of SRS 332.0 Expenses Table 4: Related party reporting (Table 4) is to capture the extent to which profit of related-connected entities of the RSE licensee is attributable to expense paid out of the assets, or assets derived from assets, of a registrable superannuation entity of the RSE licensee.
 
APRA’s expectation is that an amount should be reported where the RSE licensee has a contract with a related-connected entity and there is a margin above (or below) cost recovery. APRA would not expect to see negative amounts reported in Table 4 unless the contract price is less than the cost recovery.

Where the impact to a related connected entity's dividend payments or retained earnings attributable to RSE expense amounts and service provision are negative, the RSE licensee may report a negative amount in Table 4.

For the purpose of reporting under SRS 550.0, APRA expects RSE licensees to calculate the effective exposure for options using the delta adjusted notional value. All other derivatives (e.g. forwards, futures, etc.) should use principal amount.

Where an RSE has investments with multiple ratings from two or more rating agencies, the RSE licensee must consistently apply the lowest rating of a single agency whenever the individual ratings conflict for reporting under SRS 550.0 Asset Allocation.

Yes, consistent with current reporting under SRS 530.0 and SRS 533.0, SRS 550.0 pertains to the investments of the fund and excludes receivables and payables.

APRA expects RSE licensees to report the benchmark allocation to each strategic sector set as part of the board approved strategic asset allocation, reporting ‘Not Applicable’ for the strategic subsector fields. The sum of these allocations, excluding allocations to ‘Currency Exposure’, must equal 100%.

A strategic subsector allocation should be reported where the RSE licensee puts in place limits or targets on sectors within the strategic sector allocation, which are set by the board, committee or individual with investment delegations under the investment governance framework of the RSE licensee. The RSE licensee should report each subsector allocation on an additional row, with the strategic subsector information reported in columns 6 – 9 and the information of the strategic sector to which it underlies reported in columns 1 – 5.

The sum of the benchmark allocations for each strategic subsector should generally equal the benchmark allocation of its parent strategic sector.

Refer to the SRS 550 worked example available on the APRA Superannuation Data Transformation FAQ landing page for an example illustrating how APRA expects sector and subsector allocations to be reported.

APRA expects RSE licensees to report benchmark allocations on SRS 550.0 Table 1 Strategic Asset Allocation as the allocation targets RSE licensees have adopted to meet the investment objectives of their investment strategy under Prudential Standard SPS 530 Investment Governance (SPS 530). 

Paragraph 20(a) of SPS 530 states: 

An RSE licensee must, at a minimum, determine for each investment strategy for an investment option that includes multiple assets and/or asset classes:

a) asset allocation targets and ranges that are appropriate to the investment objectives of the investment option;

As such, APRA expects strategic asset allocation targets to be reported for each investment option that invests in multiple asset classes in SRS 550.0.

Prudential Practice Guide SPG 530 Investment Governance (paragraphs 40 and 41) provides further guidance that irrespective of asset allocation approach (e.g. dynamic asset allocation), APRA expects RSE licensees to establish formal approaches to determining asset allocations including establishing initial target asset allocations and ranges as required under SPS 530. 

APRA expects that when reporting actual asset allocation exposures under SRF 550.0 table 2, RSE licensees will report the combination of fields relating to strategic sector that aligns to a combination reported in SRF 550.0 table 1 for:

• Investment Strategic Sector Type
• Investment Strategic Sector Listing Type
• Investment Strategic Sector Domicile Type
• Investment Strategic Sector International Economy Type

Conversely, APRA expects that each combination reported under SRF 550.0 table 1 are also reported under SRF 550.0 table 2. APRA understands an RSE licensee may report no investment exposures under a strategic sector where that strategic sector’s benchmark allocation is 0%, or close to 0%.

‘Strategic Subsector’ means the segment of a ‘strategic sector’ asset class to which an asset allocation target is approved by the board, committee or individual with investment delegations under the investment governance framework of the fund.

Changes to ‘strategic subsector’ benchmark allocations (and ranges) to specific segments or groupings within that asset class may be approved under the appropriate investment delegation only where these allocations are within the Board approved allocations to the ‘strategic sector’. 

The RSE licensee should report each subsector allocation, where this is set, on an additional row, with the subsector information reported in columns 6 to 9 and the information of the strategic sector to which it underlies reported in columns 1 to 5. The sum of the benchmark allocations reported for each strategic subsector should equal the benchmark allocation for the relevant strategic sector.

Example: The Board approves a strategic sector benchmark allocation of 30% and ranges of (10 - 40%) to fixed income. The Investment Committee, Chief Investment Officer or Head of fixed income portfolio may, under delegation provided by the RSE Licensee’s investment governance framework, approve a strategic subsector benchmark allocation of 10% to Australian fixed income ex credit; 10% to Australian credit; and 10% to global fixed income. 

APRA expects RSE licensees to be able report on the investment strategy of options it offers to members consistent with the RSE licensee’s responsibility to formulate an investment strategy for each option. This includes externally managed options where an RSE licensee may adopt the investment strategy of the external investment manager. Some examples include managed funds, exchanged traded funds and listed investment companies offered on an investment platform.  

In cases where the RSE licensee adopts the investment strategy of an externally managed investment option the RSE licensee should report the investment strategy for the option as reported by the external investment manager. 

RSE licensees are not required   to report ‘Currency exposure’ as the asset class sector type in SRF 550.1 Table 1 ‘Investments’. RSE licensees are to report currency exposure for the RSE in SRF 550.1 Table 2 ‘Currency exposure’. 

All assets classified under total investments on the RSE financial statements should be reported on SRF 550.1. If this includes Operational cash, these assets should generally be classified using Asset Class Characteristic 2 ‘Cash at Bank’.

APRA expects that RSE licensees report asset allocation data for all investments held under the investment options under SRF 550.0 table 2; and all RSE investments under SRF 550.1 table 1 for each reporting period, regardless of availability of classifications as at the reporting due date.

Where investments are directly held, APRA expects RSE licensees to have all required classification information available at the reporting date. Where the investment is held through an investment vehicle – connected entity, APRA expects RSE licensees to have all required information available at the reporting date for reporting the value with the asset class characteristics classifications on an APRA-look through basis.

Where the investment is held through an investment vehicle – non-connected entity, when the required information is unavailable at the reporting date, APRA expects RSE licensees to report the value of the investment classified using the best available information. Where no classification information is available, RSE licensees should report the value of the investment with the classification as ‘Not available’ for the relevant ‘Asset Class Characteristic 1’, ‘Asset Class Characteristic 2’ and/or ‘Asset Class Characteristic 3’.

Where:

• information reported as ‘not available’ in the immediately preceding reporting period and the information becomes available during the current reporting period; or
• information was reported on a best available basis in the immediately preceding reporting period and a material difference is identified during the current reporting period,

APRA expects an RSE licensee is to submit a revised form for the relevant prior reporting period reflecting the new information by the due date for the current reporting period. 

In SRS 550.0 Table 2, the value of investments are to be reported with the actual asset allocation classification in addition to the respective strategic sector that the investments are allocated to.

APRA expects that for each investment option the combinations of strategic sector information (Investment Strategic Sector Type, Investment Strategic Sector Listing Type, Investment Strategic Sector Domicile Type and Investment Strategic Sector International Economy Type) reported in SRS 550.0 Table 2 should be the same as the equivalent combinations of strategic sector information reported in SRS 550.0 Table 1 for that investment option.

SRS 605.0 requires annual submissions in respect of each RSE as at 30 June.  

APRA expects an ad-hoc submission for SRS 605.0 where an RSE licensee makes changes to an RSE’s products, investment menus or investment options (including for example, where a new product, investment menu or option is added or removed). Changes to the characteristics of products, investment menus or options would also result in an ad-hoc submission for SRS 605.0 (including if there is a name change to the products, investment menus or options).

APRA expects an ad-hoc submission of SRS 605.0 to be triggered by:

• The addition or deletion of any row in table 1, table 2 or table 3 of SRF 605.0; or 
   
• Updates to any field of table 1, table 2 or table 3 of SRF 605.0 other than:

      o    ‘Product Disclosure Statement Updated Date’ (column 14, table 1 of SRF 605.0); 
      o    ‘Investment Option Included Count’ (column 8, table 3 of SRF 605.0) for aggregated investment options.

For example, if an aggregated investment option provides members with access to direct shares included in the ASX200, a rebalancing of the relevant index will not be a trigger for an ad-hoc submission.

Fees and costs arrangements:

APRA expects an ad-hoc submission for SRS 605.0 where an RSE licensee makes changes to fee and cost arrangements (including for example, where a new fee or cost arrangement for an employer sponsor is changed and distinct from the arrangements already reported to APRA. This includes where an existing fee or cost arrangement is removed). 

Changes to the number of employer sponsors, number of member accounts and total member benefits covered under each fee and cost arrangement are expected over the course of the year, and will not trigger the requirement for an ad-hoc submission.

Specifically, APRA expects an ad-hoc submission of SRS 605.0 to be triggered by:  

• The addition or deletion of any row in table 4 of SRS 605.0; 
   
• Updates to any field in table 4 of SRS 605.0 other than:

     o    Employer Sponsors Fees and Costs Arrangement Count; or 
     o    Member Accounts Fees and Costs Arrangement Count; or 
     o    Members Benefits Fees and Costs Arrangement Amount.

A member cannot have a beneficial interest within an RSE that is not through a superannuation product as defined under SRS 605.0.

For the purpose of reporting under SRS 605.0 and all associated reporting standards, APRA expects RSE licensees to report one or more superannuation products for each RSE.

For the purpose of reporting under SRS 605.0, APRA expects an RSE licencee to report one or more investment menus for each superannuation product. 

The concept of an investment menu is a new reporting level introduced under SRS 605.0 which represents the collection of investment options that members in a superannuation product have access to.

In the case of a lifecycle option, the investment menu represents the collection of lifecycle stages.

In some, but not all cases there may be an additional fee incurred by the members in order to access the investment options contained within the menu. 

Members in different superannuation products may have access to: 

• different investment menus (comprising differing or overlapping investment options); or, 
   
• to the same investment menus.

APRA expects investment options are reported if they either:

• have members or member assets in them; or 
   
• are open to new members, regardless of whether any members or member assets are currently invested in them.

Consistent with current reporting to APRA, if the RSE is authorised to offer a MySuper product, APRA expects they report for each generic MySuper product, goodwill MySuper product and large employer MySuper product, as a distinct superannuation product with the product type of ‘MySuper’.

APRA expects MySuper products to have a single investment menu which provides access to either:

• a single diversified investment option; or
• multiple lifecycle stages.

APRA expects that members who have 100 per cent of their balance in the MySuper product are reported under the MySuper product on SRF 606.0. APRA expects that member totals that are reported under the MySuper product and investment menu combination in SRF 606.0 table 4 would align to member totals that are reported for the MySuper product on SRF 611.0 table 2.

Where the MySuper option is accessed through other superannuation products, APRA expects that members who have less than 100 per cent of their balance in the MySuper option are reported under the non-MySuper product in combination with the MySuper investment menu (using the same unique identifier as the investment menu which is linked to the MySuper product) and relevant investment option on SRF 606.0.

Where members in the same investment option are not considered to have a MySuper interest, APRA expects that these members are reported under a non-MySuper investment menu reported in combination with that investment option.

Please refer to the worked example for SRF 605.0, SRF 606.0 and SRF 611.0 (see below) for further information.

Yes, each individual fee arrangement is required to be reported in table 4 of SRF 605.0.  If the same arrangement is offered to a number of individual members, these may be aggregated into a single reporting line.

APRA expects RSE licensees to report the URL that covers the largest number of members, and then by funds under management if another factor is required.

No, RSE licensees are not required to report member level fee arrangements which are negotiated between a member and an advisor under Table 4 of SRF 605.0 RSE structure. RSE licensees should report fee arrangements which are standard fees and costs arrangements or those that have been negotiated with the RSE licensee rather than a financial planner.

APRA will accept reporting of unique identifiers that do not identify employers by name in table 4 of SRF 605.0.

APRA expects that these items will align, however accepts that due to definitional differences these items may not be exactly equal.

Yes. There are no materiality thresholds for reporting of fee arrangements. APRA expects RSE licensees to report all fee arrangements which apply to members under table 4 of SRF 605.0. Please note that this excludes fees for advice as outlined in FAQ 706.

APRA expects that where the inception date is unclear, due to the superannuation product having a long history, the RSE licensee will report the date 1 January 1990.  

As per the definition under SRS 101, for an investment option, the inception date is the first date that the investment option was available through any investment menu within the RSE, defined benefit RSE or ERF.

APRA expects RSE licensees to report the inception date for the investment option, regardless of the date that the investment option would have met the definition of a TDP.

The standard fee arrangement should reflect the absence of any custom fee arrangement. In most cases, it is sufficient to report one standard fee arrangement which applies to all products. 

Where more than one standard fees and costs arrangement has been reported in SRF 605.0 table 4, the RSE licensees cannot report ALL under the fee and costs arrangement identifier in SRS 705.0 Components of net return, SRS 705.1 Investment performance and objectives or SRS 706.0 Fees and Costs. Instead RSE licensees must report a separate row for each fee arrangement.

APRA expects that there should be no more standard fees and costs arrangements than products reported.

APRA expects that for column 10 in SRF 605.0 table 3 titled ‘Exchange Code Text’ the code of the exchange on which any exchange-traded assets are listed is to be reported and not the ticker symbol or individual security identifier.

For example, for an ASX listed security, column 10 would be reported as ASX, while column 11 of SRF 605.0 table 3 titled ‘Ticker Symbol Text’ would be the ticker code or the individual security identifier.

APRA expects RSE licensees to report the ‘Investment Option Name Text’ consistent with how the investment option name is disclosed to members. The ‘Investment Option Name Text’ reported to APRA should not contain codes or shorthand text.

For the purpose of reporting ‘Investment option management type’ and ‘Investment option strategy setting type’ a ‘connected entity’ has the meaning as in section 10 (1) of the SIS Act.

Where each entity that manages investments in respect of the investment option is a connected entity, the RSE licensee must report: ‘Externally managed – connected entity’.

Where at least one entity that manages investments in respect of the investment option is not a connected entity, the RSE licensee must report: ‘Externally managed – non connected entity’.

APRA expects that the number of defined benefit members as at the reporting date that would be included for actuarial valuation purposes is reported (for member benefits which the assets in the investment option underlie). 

APRA intends to update the reporting instructions to clarify that where a combination of a fees and costs arrangement with an investment pathway had members or assets invested in it at any time during the reporting period it should be reported in SRF 606.1 Table 2: Member accounts (fee and cost arrangements). This includes instances where the combination has no members or assets invested at the end of the reporting period.

Combinations where there were no members or assets invested at any point during the reporting period do not need to be reported.

APRA intends to update the reporting instructions for SRF 606.1 to clarify that where a combination of a fees and costs arrangement with an investment pathway had members or assets invested in it at any time during the reporting period it should be reported in SRF 606.1 table 2: Member accounts (fee and cost arrangements). This includes instances where the combination has no members or assets invested at the end of the reporting period.

Combinations where there were no members or assets invested at any point during the reporting period do not need to be reported.

Yes, APRA expects all RSE licensees to report all members of the RSE in Table 1 of SRF 611.0 Member Accounts.

Where the RSE licensee is unable to calculate a member benefit value for a member in a product such as annuity products, RSE licensees may report a value of zero for the member benefit. For example, if this is the only interest held by the member, the member may be included in the ‘Member Benefit Bracket Type’ of ‘<$1000’.

APRA expects RSE licensees to report defined benefit members’ benefits based on: 

• data from the most recent actuarial valuation; or 
• an other calculation or update approved by the fund actuary. 

No, activity-based fees will be reported in relation to fee and cost disclosures via SRS 706.0.

APRA notes that investment performance will include accruals for various components of net returns, such as performance fees and taxes; some of these components would include estimates.  APRA expects that components of net returns reported under SRS 705.0 reflect the net return a member in that option / product would receive for the reporting quarter, including accruals and any adjustments made during the reporting quarter.    

ARPA expects that the gross investment return reported under SRS 705.0 and SRS 705.1 will reflect the most accurate representation of the gross performance of the investment option given the information available at the due date. 

In accordance with FAQ 705.0b, APRA notes that quarterly investment performance will include accruals for various components of net returns, such as performance fees and taxes; some of these components would include estimates. APRA expects that the gross investment return reported under SRS 705.0 would reflect the net investment return a member in that option / product would receive for the reporting quarter, grossed up by the quarterly accrual for investment fees, costs and taxes reported under SRS 705.0 for the reporting quarter.  

APRA expects the annual submission of SRS 705.0 to reflect the actual fees costs and taxes for the year.

APRA's expectation is that the Net Investment Return is calculated as investment earnings as a proportion of the members’ balance attributed to an investment option, consistent with how that return is disclosed to members.

APRA generally expects these returns to match but will allow a tolerance for rounding.

RSE licensees must report administration fees and costs for each quarter and annually for the year ending 30 June for all products and menus, regardless of the investment options available through the products and menus. 

RSE licensees must report the gross investment return, as well as other components of net return excluding ‘indirect costs (non-RSE licensee)’ for investment options for each quarter and annually for the year ending 30 June. 

As per the minor amendments response letter dated 3 March 2023, APRA included a new concept of 'indirect costs (non-RSE licensee)' under SRS 705.0 to facilitate less frequent reporting of these indirect costs for external product options. 

The reporting period in respect of ‘indirect costs (non-RSE licensee)’ is annually for the year ending 30 June. RSE licensees are not required to report ‘indirect costs (non-RSE licensee)’ for investment options each quarter. However, if the data are available quarterly, RSE licensees may elect to also report this on a quarterly basis.

APRA will interpret the gross investment return reported as the net investment return grossed up by all reported investment-related fees, costs, and taxes.

APRA expects RSE licensees to report investment objectives as per SPS 530 Investment Governance, not peer benchmarks.

APRA notes that there is a difference between the reporting standard which specifies that numbers should be reported as percentages to 2 decimal places and APRA Connect which allows percentage up to 4 decimal places (6 decimal places in total).  

RSE licensees should report data for these columns to 4 decimal places (for percentages this will mean 6 numbers after the decimal point). APRA intends to update this requirement the next time the reporting standard is determined.

Under Superannuation Prudential Standard 530 Investment Governance, APRA expects that an investment return objective be specified and measurable. SPG 530 states that ‘APRA expects a return objective would be expressed with a defined investment horizon…’.

APRA expects RSE licensees to report the time horizon used to set the return objective target in SRF 705.1 table 1 column 10. APRA expects this to be consistent with the defined investment horizon set out in the RSE licensee’s Investment Policy Statement.

Where the return objective investment horizon is defined as a range, or consists of multiple time horizons, report the minimum investment horizon the return objective is measured against.

If an RSE licensee is unable to source the relevant time horizon for a historical reporting period, the RSE licensee may report the investment horizon adopted for the most recent reporting period available.

For defined benefit products, report only fees and costs that are charged to members.

Yes, SRS 706.0 requires that all standard and customised fee structures are reported.  

Changes in buy/sell spreads on their own do not trigger an ad hoc submission of SRS 706.0. 

No. Member level advice fee arrangements that have been agreed between a member and a financial adviser are not required to be included in reporting for SRF 706.0.

RSE licensees must report data under SRS 706.0 annually each 30 June and ad-hoc within 28 days of a change to fees and costs reported under SRS 706.0.

All fees and costs data under SRS 706.0 should be reported as the annual fee disclosed or the fee per activity disclosed as at the reporting date. Where a fee or cost is calculated or charged more frequently than annually, the RSE licensee should report the calculation frequency in column 10, and the charge frequency in column 11. The RSE licensee should report the percentage or dollar charge in column 17 or 20 as the fee or cost per annum regardless of the calculation or charge frequency. Where a fee or cost is calculated or charged per activity, the RSE licensee should report the percentage or dollar charge as the fee or cost per activity. 

RSE licensees do not need to report the fee cap of 3% per annum of the account balance on investment and administration fees for all accounts with balances less than $6,000. As this fee cap is prescribed in legislation, APRA will apply this to all RSE licensees in use of the data.