Skip to main content

Frequently Asked Questions - Superannuation Data Transformation

These frequently asked questions (FAQs) provide timely guidance on commonly asked questions about reporting. 

The questions are designed to clarify reporting issues raised by RSE licensees. APRA encourages entities to report to APRA in accordance with the guidance provided here to the extent practicable. The FAQs refer to APRA’s reporting standards however, until the guidance is formally incorporated into the legislative reporting instruments, it does not form part of the law or create enforceable requirements.

It is APRA’s practice, where appropriate, to incorporate this guidance into the final reporting standards, forms and instructions periodically. When this occurs, APRA provides formal notice to entities and removes the questions from this page. For reference purposes only, APRA will archive questions that contain guidance on matters that have been incorporated in the final reporting standards, forms and instructions.

Note: The numbering of the questions is fixed and will not change as new questions are added.

Updated: 8 October 2021.

Phase 1 Reporting Standards

General FAQs

1.01: Can all the reports be submitted in Excel format via APRA Connect?

Accepted file submission formats are as noted on the APRA Connect technical specifications page on the APRA website.

Accepted submission formats for the Superannuation Data Transformation Phase 1 reporting standards are: Manual entry, XML, and Excel.

1.02: What are the due dates for submission of data under the new reporting standards?

The due date for the first submission of data in all the new superannuation forms for the reporting period ending 30 June 2021 has been extended to due by 28 October 2021. 

Any ad-hoc submission of the new superannuation forms required due to a change will be due by the later date of 28 calendar days after the change, or 28 October 2021.
 
For these four reporting forms:

  • “SRF 705.0 Components of Net Return” (SRF 705.0)
  • “SRF 705.1 Investment Performance and Objectives” (SRF 705.1)  
  • “SRF 550.0 Asset Allocation” (SRF 550.0)
  • “SRF 706.0 Fees and Costs Disclosed” (SRF 706.0)
  1. RSE licensees must report data for the periods ending 30 June 2021 and 30 September 2021 for MySuper and trustee-directed products by 28 October 2021. 
     
  2. RSE licensees must report data for periods ending on or after 30 June 2021 up to and including 30 June 2022 which relates to any other product, investment menu or investment option, by 28 July 2022.  

In accordance with SRS 550.0 Asset allocation, the first mandatory reporting period for the following forms is the period ending 30 June 2022: 

  • “SRF 550.1 Investments and currency exposure” (SRF 550.1); and  
  • “SRF 550.2 Derivatives and counterparty exposure” (SRF.550.2).

RSE licensees that are in a position to provide the full coverage of reporting earlier are encouraged to do so.

The following table summarises the reporting periods and extended due dates under the Superannuation Data Transformation reporting standards:

Return

Frequency

Due date

Fir­­st reporting period

First due date

Next reporting period

Next due date

SRS 605.0 RSE Structure

Annual*

28 days**

30/06/2021

28/10/2021

30/06/2022

28/07/2022

Ad-hoc

28 days***

When information is no longer accurate (as per para 9 of SRS 605.0)

28 days later***

When information is no longer accurate (as per para 9 of SRS 605.0)

28 days later

SRS 606.0 RSE Profile

Quarterly

28 days**

30/06/2021

28/10/2021

30/09/2021

28/10/2021

SRS 611.0 Member Accounts

Quarterly

28 days**

30/06/2021

28/10/2021

30/09/2021

28/10/2021

SRS 705.0 Components of Net Return

Quarterly

28 days**

30/06/2021

28/10/2021

30/09/2021

28/10/2021

Annual

3 months

30/06/2021

28/10/2021

30/06/2022

30/09/2022

SRS 705.1 Investment Performance and Objectives

Quarterly

35 days**

30/06/2021

28/10/2021

30/09/2021

04/11/2021

SRS 550.0 Asset Allocation

SRF 550.0

Quarterly

28 days**

30/06/2021

28/10/2021

30/09/2021

28/10/2021

SRF 550.1

Quarterly

28 days**

30/06/2022

28/07/2022

30/09/2022

28/10/2022

SRF 550.2

Quarterly

28 days**

30/06/2022

28/07/2022

30/09/2022

28/10/2022

SRS 251.0 Insurance Arrangements

SRF 251.0

SRF 251.1

SRF 251.2

SRF 251.3

Annual

3 months

30/06/2021

28/10/2021

30/06/2022

30/09/2022

SRF 251.3

Ad-hoc

28 days***

When information is no longer accurate (as per para 12 of SRS 251.0)

28 days later***

When information is no longer accurate (as per para 12 of SRS 251.0)

28 days later

SRS 332.0 Expenses

Annual

3 months

30/06/2021^

28/10/2021

30/6/2022^

30/09/2022

SRS 706.0

Fees and Costs

Annual*

28 days**

30/06/2021

28/10/2021

30/06/2022

28/07/2022

Ad-hoc

28 days***

When information is no longer accurate (as per para 9 of SRS 706.0)

28 days later***

When information is no longer accurate (as per para 9 of SRS 706.0)

28 days later

​​​​* Quarterly attestation required 28 calendar days after the end of each calendar quarter
** 28 calendar days after the end of the reference period. For SRS 705.1, 35 calendar days after the end of the reference period for each reporting period ending on or after 30 June 2021 but before 30 June 2022.
*** 28 calendar days after the change has occurred. If 28 calendar days after the change is prior to the due date of the initial submission, then the due date will be the same as the initial submission due date.
^ SRS 332.0 requires reporting aligned with each year of income of the RSE. For example, an RSE that has a 31 December year end would report SRS 332.0 for the year ending 31 December 2021, with its first submission of SRS 332.0 due on 31 March 2022.​​​​

1.03: Do reporting standards from the existing data collection still need to be submitted? 

Yes. APRA recognises there is a degree of overlap between data to be collected through the new reporting standards and data collected under existing reporting standards.  The existing reporting standards will continue for an initial parallel collection period, primarily to enable APRA to assess data quality for the new reporting standards. Once appropriate quality of reporting under the new framework is achieved, APRA intends to  provide exemptions from reporting obligations and/or revoke reporting standards which require the same data that is to be submitted under the new data collection.

1.04:  Can APRA provide more information about the consultation on confidentiality and the publication of data collected under the new reporting standards?

APRA will undertake a separate consultation in late 2021 on proposals for publication of data reported under these reporting standards, including consulting on the confidentiality of the specific data items that APRA intends to publish.

1.05  When will APRA provide a definition for trustee-directed products?

The SIS regulation which defines a trustee-directed product was made on 5 August 2021. APRA intends to update SRS 101.0 to include the definition for trustee-directed products as follows:

Trustee-directed product: Has the meaning given by subregulation 9AB.2(2) of Superannuation Industry (Supervision) Regulations 1994 (SIS).

1.06  We may be in a position to report data which is not required under the staged approach for 30 September (e.g. data for all investment options; expense classifications with no materiality; or all asset allocation characteristics), will APRA allow submission of this data?

Yes, RSE licensees that are in a position to provide full reporting earlier will be able to do so.

1.07 How can we keep track of updates to validation rules as we approach the first collection of data on 30 September 2021?

Validation rules for the new reporting standards can be viewed at the APRA Connect Taxonomy Artefacts page. APRA will post alerts via its subscriber list for updates to the Taxonomy Artefacts.

The draft artefacts include the data dictionary, validations, reporting taxonomy and XSD (to validate the structure of XML files). While every effort has been made to ensure accuracy, entities can expect further changes before APRA Connect goes live.

Updated versions of the artefacts will be available prior to the release of the external test environment in June.

1.08 Should fees and costs be reported as they are presented in the Product Disclosure Statement (PDS) where the disclosed amounts are net of tax rebates?

APRA expects that all fees and costs will be reported gross of tax to ensure that there is consistency in reporting. For the avoidance of doubt, APRA intends to remove the line ‘consistent with the manner in which they are required to be disclosed in PDS’ in the ‘Reporting basis and unit of measure’ section of Reporting Standard 706.0 Fees and Costs.

1.09 What will be the process for the submission of historical data?

Returns for each historical reporting period covered under the required timeframe will be available on APRA Connect for RSE Licensees to submit historical data.

1.10: What are the audit requirements for the new reporting standards? SPS 310 Audit and Related Matters (SPS 310) does not include the new reporting standards?

APRA intends to consult on specific audit requirements for the new reporting standards as part of the review of the approved audit form under SPS 310 in the second half of 2021. For the 30 June 2021 annual reporting period there are no specific audit requirements beyond those detailed in Part 3 (B) Controls and Compliance in the approved audit form.

1.11 What is the initial due date for reporting on trustee-directed products?

The SIS regulation which define a trustee-directed product was made on 5 August 2021. APRA will extend the due date for submission of 30 June 2021 data for trustee-directed products from 30 September 2021 to 28 October 2021 to allow sufficient time to implement reporting. RSE licensees that are in a position to provide the full coverage of reporting earlier are encouraged to do so.

In APRA’s response to consultation the staged implementation approach introduced temporary reduced coverage, with the first year of reporting on products, investment menus and investment options only including data on MySuper and trustee-directed products for the following four reporting forms:

  • “SRF 705.0 Components of Net Return” (SRF 705.0)
  • “SRF 705.1 Investment Performance and Objectives” (SRF 705.1)  
  • “SRF 550.0 Asset Allocation” (SRF 550.0)
  • “SRF 706.0 Fees and Costs Disclosed” (SRF 706.0)

RSE licensees must report 30 June 2021 data for MySuper products by 30 September 2021. 

1.12: What are the reporting requirements for Pooled Superannuation Trusts (PST) in the new Superannuation Data Transformation reporting standards?

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.

1.13: What does APRA expect to be attested to each quarter?

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.

1.14 Do I need to complete new Superannuation Data Transformation (SDT) returns in any particular order?

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:

1.15 Where can I find information about what was updated in the determined SDT reporting standards released in September 2021?

APRA has published the SDT reporting standards with marked up changes here.

1.16 Where can I find information about the release history and changes to versions of APRA Connect artefacts?

APRA has published a log of the changes to all versions of the APRA Connect artefacts issued at APRA Connect Taxonomy Artefacts. The latest version of the artefact file was released on 19 August 2021. 

The log includes:

  • Schema: changes to elements, enumerations, etc;
  • Validation rules: new or amended validation rules; and
  • Rule restrictions: validation rules that have been restricted. 

A summary of taxonomy artefact changes can be found here:

FAQs for SRS 251.0

251.0 a: Could APRA please clarify the reporting for 'number of policies in cluster' (SRF 251.0 table 1 column 7)? 

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). 

251.0 b: Under table 1 of SRS 251.0, are underwritten policies to be counted as separate 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).

251.0 c: How does APRA expect an entity to categorise their occupation ratings into the categories provided under SRS 251.0?

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.

251.0 d: For insurance offerings where there has been a successor fund transfer over the historical period(s) is it expected that the premiums paid, and the claims history, be reported for the members that were transferred?

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.

251.0 e: When is the 5 years of historical data required by SRS 251.0 Insurance Arrangements table 2 due for submission?

APRA intends to update ‘SRS 251.0 Insurance Arrangements’ to allow RSE licensees up until 28 February 2022 for the submission of 5 years of historical data for SRF 251.2 Insurance Payments (years ending 30 June 2016 – 2020). 

251.0 f: RSE licensees may need to report activity on policies for the historical data collection periods under SRF 251.2 which may not have been in force during the five years prior to 30 June 2021. How should RSE licensees report these policies under SRF 251.0?

It will not be necessary to complete SRF 251.0 for each historical reporting period. APRA intends to clarify the instruction in SRS 251.0 for Table 1 of SRF 251.0. For the 30 June 2021 submission period only, RSE licensees must report all insurance policies currently or previously held by the RSE licensee for which one or more of the following activities occurred during the five years prior to the start of the reporting period:

a) premiums were paid to the insurer; or
b) claims were received, processed or paid.

In addition to the requirement to report all insurance policies currently or previously held by the RSE licensee which:

1. were in force at any time during the reporting period or in the 5 years prior to the start of the reporting period; or 

2. for which one or more of the following activities occurred during the reporting period:

a) premiums were paid to the insurer; or
b) claims were received, processed or paid.

251.1 a: Should 'No' for the item 'default cover offered' (SRF 251.1 table 2, column 3) be selected if any members have moved away from the default level of cover?

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.

251.1 b: For cohorts of members with default insurance cover who were migrated to an insurance policy that does not offer default cover, are these  considered as default for the purposes of reporting the item ‘Insurance Default Cover Offered Indicator’ on Table 1 of  SRF 251.1?

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).

251.1 c When a member retains the same insurance cover but has switched superannuation products during the reporting period, how should this be reported in SRF 251.1 table 1?

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. 

251.2 a: If a payment is made to an insurer in the 2021 reporting period but this payment relates to prior cover periods, how should this payment be reported in SRF 251.2 Table 1?

The RSE licensee should report the period the payment relates to in ‘Insurance Cover Year Date’ column (SRF 251.2, Table 1, Column 3).  APRA expects any payment which relates to multiple years of cover to be split into amounts for each year of cover that it applies.

251.2 b: For the reporting of claim payments in SRF 251.2 when is the claim payment made? 

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

251.2 c: In cases where a member’s account balance has been paid in addition to claim amounts (for example in life or TPD claims), should the item ‘Insurance claim paid amount’ (column 5 of SRF 251.2 table 3) reflect the total amount paid out or just the claim amount?

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.

251.2 d:  Where data for ‘Assessment Criteria Total And Permanent Disability Type’ (column 2, table 5 of SRF 251.2) is not readily available for a period of time for the historical data collection under SRF 251.2, what should be reported?

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).

251.3 a: For the item 'age' (SRF 251.3 table 2 column 3) is it possible to report age-bands (i.e., 11-20, 21-30 and so on)  If yes, age as at what date in time?

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. 

251.3 b:  For insurance offerings that are either partially or fully funded by the members’ employer, should these amounts be included when reporting ‘Insurance Cover Cost Amount’ (SRF 251.3 Table 2, Column 10)?

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’.

251.3 c: For insurance offerings that have no default component, is APRA expecting data to be reported in SRF 251.3?

RSE licensees are only required to report data for insurance policies which provide default cover to members as indicated on SRF 251.3 Table 2. RSE licensees should report policies which are closed to new members as well as policies which are open to new members.

251.3 d: How should data for insurance clusters with bundled cover in SRF 251.3 be reported? 

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. 

251.3 e: How should an insurance cluster that is offered to multiple occupation categories be reported in SRF 251.3?

APRA expects that where different premium rates apply to different occupation categories, 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 occupation categories, then these should be reported as a single row in table 1 of SRF 251.3 as per FAQ 251.0c.

251.3 f: Do insurance policies that are priced individually for different employer plans need to be reported separately under SRF 251.3?

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. 

251.3 g: How should default cover and the cost of cover for insurance that varies based on salary, future years of service or other factors be reported under 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’.
 

FAQs for SRS 332.0

332.0 a: How should SRS 332.0 be reported if an RSE has a year-end that is not 30 June?

SRS 332.0 provides that reporting periods for this reporting standard are for each year of income of the entity.

For example, an RSE that has a 31 December year end would report SRS 332.0 for the year ending 31 December, with its submission due on 31 March.

332.0 b: SRS 332.0 Expenses states that amounts in SRF 332.0 should and are to be reported on an accrual basis. However, the instructions refer to expenses paid to suppliers over the period . Can APRA clarify its expectations?

As per the reporting basis section, reporting under SRS 332.0 Expenses should reflect expenses accrued. APRA intends to update references to ‘payments’ and ‘expenses paid’ in the reporting instructions to ‘expenses’ .

332.0 c: How should accounting concepts such as depreciation be reported under SRS 332.0 Expenses?

APRA expects RSE licensees to report a row in Table 1 with the name ‘Accounting concepts’ for the purpose of reporting accounting concepts such as depreciation. The total amount of depreciation should be reported in Table 2 with the expense group type ‘Corporate overheads’ and expense type ‘Amortisation And Depreciation’. 

APRA expects other accruals adjustments relating to the provision of goods or services to be reported with the ‘Accruals adjustment’ service provider identifier against the relevant expense group type and expense type.

332.0 d: What should be reported if a supplier does not have an ABN?

Where a supplier does not have an ABN, this field can be left blank. APRA intends to make the ABN a non-mandatory field. This will be reflected in the next release of APRA Connect and the associated taxonomy artefacts.

332.0 e: How should expenses relating to preparing data for APRA reporting be captured in SRS 332.0?

Expenses relating to the preparation of APRA returns should be included in the expense group ‘Corporate Overheads’ and expense type ‘Other’. The ‘Service Arrangement Inclusions Exclusions Text’ should be used where there is not a relevant category.

332.0 f: How should the wages of internal teams, (such as human resources, which do not relate to one of the services described by an expense type), be reported under SRS 332.0?

Expenses relating to the wages for corporate overheads such as human resources should be included in the expense group ‘Corporate Overheads’ and expense type ‘Other’ with the RSE licensee as the service provider. A description may be provided in ‘Service Arrangement Inclusions Exclusions Text’ if additional context is required. 

Wages for internal teams which provide a service which has an expense type listed should be reported under that category. For example, internal call centre staff wages should be reported as expense group type ‘administration’, expense type ‘call centre’, with the RSE licensee as the service provider.

332.0 g: What is a one-off vs an ongoing ‘Service Arrangement Engagement Type’?  When there is a service arrangement that continues over one or more reporting periods is this an ongoing ‘Service Arrangement Engagement Type’?

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.

332.0 h: RSE licensees have not had processes in place to capture these classifications for the year ending 30 June 2021. What are APRA’s expectations for the initial year of reporting? - Superceded by 332.0 q

APRA intends to update SRS 332.0 to permit RSE licensees to report on SRF 332.0 on a best endeavours basis for periods ending before 30 June 2022, except for expenses used for the purpose of the following expense types: 

  • Marketing related expenses (including: Advertising or Marketing, Existing Member Campaigns, Member Acquisition Campaigns, and all expense types under Marketing And Distribution (expense group)); 
  • Sponsorship;
  • Payments Or Donations To Industry Bodies;
  • Payments Or Donations To Political Parties;
  • Payments Or Donations To Trade Bodies.

APRA expects RSE licensees to report the total expenses of the RSE, and to report a Service Arrangement Cost Amount for each expense type for which a service is provided to the RSE.

APRA expects RSE licensees to have plans and processes in place to improve reporting prior to the submission of the 30 June 2022 reporting.

332.0 i: How should accruals be reported where they cannot be mapped to a service provider?

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.

332.0 j: How should Director fees that are paid to another organisation, rather than to the director themselves, be reported?

SRS 332.0 is designed to capture information related to the flow of member money as well as the purpose for the deduction. Data on Director remuneration is reported to APRA under SRS 600.0 ‘Profile and Structure’ (RSE Licensee).    

Where Director fees are paid to an entity rather than to the Director themselves, the entity  should be reported in table 1 ‘Service providers'. Reporting should include the total amount paid to the entity in table 2 against the Service provider Identifier for that entity.

If the receiving entity is captured under one of the other expense type categories such as ‘Payments to trade bodies’, entities should report the amount under that category, with the description in the inclusions/exclusions text being ‘payments in lieu of director fees’. Otherwise, entities should report under the group expense type ‘Trustee office’ and the expense type ‘Directors fees’.

332.0 k: Where a service provider is paid a single fee for multiple services, how should this be reported?

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. 

332.0 l: Can APRA clarify the definition for ‘Payments or Donations to Industry Bodies’ and ‘Payments or Donations to Trade Bodies’?

APRA intends to update the definition for ‘Payments or Donations to Industry Bodies’ to mean the expense incurred for the provision of payment or donations to industry associations.

APRA intends to update the definition for ‘Payments or Donations to Trade Bodies’ to mean the expense incurred for the provision of payments or donations as defined in 2.10 (1)(g) of the Superannuation Industry (Supervision) Regulations 1994. 

332.0 m: What is the definition of related party under SRS 332.0?

APRA intends to define related party for SRS 332.0 to mean, in relation to an entity (the principal entity) or the RSE licensee of the principal entity, the entities described in regulation 2.10(1)(h)(i) – (vi) of the Superannuation Industry (Supervision) Regulations 1994. 

332.0 n: How does APRA expect profit to be reported under SRS 332.0? Does APRA expect reporting entities to obtain information on the profit of service providers who are not related parties of the RSE licensee?

APRA intends to update SRS 332.0 to clarify that entities are expected to report the extent to which the receiving entity’s profit is attributable to that expense amount, only where the receiving entity is the RSE licensee or a connected entity, which is also a related party. Connected entity means a person connected with an RSE licensee under subsection 13(4F) of the Financial Sector (Collection of Data) Act 2001. Related party means, in relation to an entity (the principal entity) or the RSE licensee of the principal entity, the entities described in regulation 2.10(1)(h)(i) – (vi) of the Superannuation Industry (Supervision) Regulations 1994.

APRA intends to clarify the definition of ‘profit payments’ in SRS 101.0 to:  expenses incurred for any profit.

332.0 o: Where expenses are paid to a connected entity, what look-through is required?

APRA intends to update SRS 332.0 to clarify how amounts are to be reported on a look-through basis for connected entities:

Where the expense is in relation to money, consideration or any other benefit given to an entity (the receiving entity) by the RSE licensee or a connected entity (the paying entity), APRA expects RSE licensees to obtain information about the following for reporting in table 1 of SRF 332.0:

  • details of the receiving entity; and
  • the relationship between the receiving entity and the RSE licensee.

APRA expects RSE licensees to obtain information about the following, in order to classify relevant amounts under the relevant expense group type and expense type categories for reporting in tables 2 and 3 of SRF 332.0:

  • the purpose for which the money, consideration or other benefit is given; and
  • the way in which the money, consideration or other benefit is used by the receiving entity, and any entity with which that entity deals. This includes, for a related connected entity, the extent to which the receiving entity’s profit is attributable to that money, consideration or other benefit in order to classify relevant amounts under the expense type ‘profit’.

332.0 p: In table 1 of SRF 332.0, what materiality should be applied when reporting relationships of responsible persons of the RSE licensee to the service provider?

APRA intend to update SRS 332.0 to clarify the instructions in ‘Responsible Person Service Provider Relationship Indicator’ (SRS 332.0, table 1, column 7) and ‘Responsible Person Service Provider Relationship Text’ (SRS 332.0, table 1, column 8)  with the following: 

If responsible persons have a relationship with the service provider which may result in a relevant duty or a relevant interest in accordance with Superannuation Prudential Standard SPS 521 Conflicts of Interest, report details of the relationship with the service provider.

332.0 q: What are APRA’s expectations for reporting under SRS 332.0 under the staged implementation approach?

Under the staged implementation approach, APRA will permit RSE licensees to report certain information on a best endeavours basis for a defined period of time. To improve clarity of drafting, the scope of data that may be submitted on a best endeavours basis has been removed from the reporting standard and provided as guidance. Despite this change, there will be no difference in how APRA will administer compliance with reporting of information which can be submitted on a best endeavours basis. 

APRA will permit RSE licensees to complete SRF 332.0 on a best endeavours basis for each reporting period ending on or after 30 June 2021 but before 30 June 2022, except for expenses used for the purpose of the following expense types:

  • Marketing related expenses (including: Advertising or Marketing, Existing Member Campaigns, Member Acquisition Campaigns, and all expense types under Marketing And Distribution (expense group));
  • Sponsorship;
  • Payments Or Donations To Industry Bodies;
  • Payments Or Donations To Political Parties; or
  • Payments Or Donations To Trade Bodies.

RSE licensees must report the total expenses for the RSE, and report a service arrangement cost amount for each expense type for which a service is provided to the RSE.

APRA expects RSE licensees to have plans and processes in place to improve reporting prior to the submission of data for reporting periods ending on or after 30 June 2022.

FAQs for SRS 550.0

550.0 a: Under APRA’s framework, how should effective exposure be calculated for options and all other derivatives?

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.

550.0 b: For asset characteristics reported on a ‘best endeavours’ basis under the staged implementation  what value should be reported where we are not able to determine the classification?

Under the staged approach, for asset characteristics to be reported on a best endeavours’ basis, where the classification cannot be determined, RSE licensees should report ‘Not Applicable’.

550.0 c: The rating-levels commonly used to determine whether a fixed income security is investment grade or non-investment grade differs to APRA’s definitions for these characteristics. Is this intentional?

APRA notes and accepts this feedback and will correct the definition for  ‘Investment Grade’ and ‘Non-Investment Grade’ for Asset Characteristic 1 for Fixed Income in Reporting Standard SRS 550.0 Asset allocation as follows:

Investment Grade: Means a debt security with counterparty rating of Grade 1 to Grade 4.

Non-Investment Grade: Means a debt security with counterparty rating of Grade 5 and below.

550.0 d: Where more than one ratings service is subscribed to and the rating does not align to a consistent grade across providers, which grade should be used?

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.

550.0 e: Are all receivables and payables excluded from 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.

550.0f: Which asset class characteristics will APRA accept reporting on a best endeavours basis for the first year of reporting? - Superceded by 550.0 j

APRA intends to update SRS 550.0 to expand the subset of characteristics in SRF 550.0 table 2 for which RSE licensees will be permitted to report on a best endeavours basis for periods ending on or after 30 June 2021 but before 30 June 2022. The intended update to SRS 550.0 will mean that following subset of characteristics are to be reported as follows:

  • Where the asset class sector type is Fixed Income, an RSE licensee must report asset class characteristic 2.
  • Where the asset class sector type is Fixed Income, an RSE licensee will be permitted to report asset class characteristic 1, asset class characteristic 3 and Investment Modified Duration Number on a best endeavours basis.
  • Where the asset class sector type is Alternatives, an RSE licensee must report asset class characteristic 2.
  • Where the asset class sector type is Cash, Property, Equity or Infrastructure, an RSE licensee will be permitted to report asset class characteristic 1, asset class characteristic 2 and asset class characteristic 3 on a best endeavours basis.

APRA expects RSE licensees to have plans and processes in place to improve reporting classifications prior to the submission of the 30 June 2022 reporting.

550.0 g: What methodology does APRA expect RSE licensees to apply to calculate the modified duration where an RSE licensee aggregates fixed income securities for reporting in table 2 of SRF 550.0 and table 1 of SRF 550.1?

APRA expects RSE licensees to apply an asset weighted duration using the effective exposure.

550.0 h: Can APRA provide clarity as to how asset class Characteristic 2 for the ‘Alternatives’ asset class sector should be applied?

APRA intends to clarify the instructions in the SRS 550.0 to instruct RSE licensees to report: 

  • commodities using the Investment Asset Class Sector Type ‘Alternatives’ with Investment Asset Class Characteristic 2 as ‘Alternatives Commodities’; 
  • alternative strategy funds using the Investment Asset Class Sector Type ‘Alternatives’ with the Investment Asset Class Characteristic 2 which best represents the primary investment strategy of the fund; and
  • other alternative assets using the Investment Asset Class Sector Type ‘Alternatives’ with Investment Asset Class Characteristic 2 as ‘Alternatives Other’.

Where ‘Alternative strategy funds’ are defined as:

Means a collective investment that displays a combination of the following characteristics: 

(a) borrowing and leverage restrictions, which are typically included in collective investment-schemes related regulation, are not applied, may use high levels of leverage;
(b) significant performance fees (often in the form of a percentage of profits) are paid to the manager in addition to an annual management fee;
(c) investors are typically permitted to redeem their interests periodically (e.g. quarterly, semi-annually or annually); 
(d) significant ‘own’ funds are often invested by the managers; 
(e) derivatives are used, often for speculative purposes, and there is an ability to short sell securities; and 
(f)  more diverse risks or complex underlying products are involved.  

550.0 i: Should infrastructure investments through quasi-government entities, public/private partnerships and owner versus operator arrangements be classified as ‘Government’ or ‘Non-Government’?

APRA expects such arrangements to be classified as ‘Government’. APRA will consider implementing a category to capture these arrangements in the future.

550.0 j: What reporting does APRA expect under the staged implementation approach for SRS 550.0?

Under the staged implementation approach, APRA will permit RSE licensees to report certain information on a best endeavours basis for a defined period of time. To improve clarity of drafting, the scope of data that may be submitted on a best endeavours basis has been removed from the reporting standard and provided as guidance. Despite this change, there will be no difference in how APRA will administer compliance with reporting of information which can be submitted on a best endeavours basis. 

APRA will permit RSE licensees to complete SRF 550.0 table 2 and SRF 550.1 table 1 on a best endeavours basis for certain asset class characteristics for periods ending on or after 30 June 2021 but before 30 June 2023. 

APRA expects RSE licensees to have plans and processes in place to improve reporting classifications.

SRF 550.0 Asset Allocation

The characteristics which are permitted to be reported on a best endeavours basis for different reporting periods on SRF 550.0 are as follows:

For each reporting period ending on or after 30 June 2021 but before 30 June 2022, an RSE licensee must, in respect of investment options underlying a MySuper product or trustee-directed product, report the information required under each table of SRF 550.0. For this period, a reduced list of asset class characteristic 1, asset class characteristic 2 and asset class characteristic 3 applies for Table 2: 

  • Where the asset class sector type is Cash, Property, Equity or Infrastructure, report asset class characteristic 1, asset class characteristic 2 and asset class characteristic 3 on a best endeavours basis. 
  • Where the asset class sector type is Fixed Income or Alternatives, an RSE licensee must report asset class characteristic 2. Report asset class characteristic 1, asset class characteristic 3 and Modified Duration on a best endeavours basis. 

Refer to Appendix A in SRS 550.0: Asset class hierarchy for the asset class characteristics which apply to each asset class sector type.

For each reporting period ending on or after 30 June 2022 but before 30 June 2023, an RSE licensee must report the information required under each table of SRF 550.0. For this period, a reduced list of asset class characteristic 1, asset class characteristic 2 and asset class characteristic 3 applies for Table 2. 

  • Where the asset class sector type is Property, Equity (where the listing type is unlisted) or Infrastructure, an RSE licensee must report asset class characteristic 1. Report asset class characteristic 2 and asset class characteristic 3 on a best endeavours basis. 
  • Where the asset class sector type is, Equity (where the listing type is listed), report asset class characteristic 1, asset class characteristic 2 and asset class characteristic 3 on a best endeavours basis. 
  • Where the asset class sector type is Cash, Fixed Income or Alternatives, an RSE licensee must report asset class characteristic 1, asset class characteristic 2 and asset class characteristic 3. 

Refer to Appendix A in SRS 550.0: Asset class hierarchy for the asset class characteristics which apply to each asset class sector type.

For each reporting period ending on or after 30 June 2023, an RSE licensee must report the information required under SRF 550.0. For each of these reporting periods, all asset class characteristics apply.

SRF 550.1 Investments and Currency Exposure

The characteristics which are permitted to be reported on a best endeavours basis for different reporting periods on SRF 550.1 are as follows:

For each reporting period ending on or after 30 June 2022 but before 30 June 2023, an RSE licensee must report the information required under each table of SRF 550.1. For this period, a reduced list of asset class characteristic 1, asset class characteristic 2 and asset class characteristic 3 applies for Table 1: 

  • Where the asset class sector type is Property, Equity (where the listing type is unlisted) or Infrastructure, an RSE licensee must report asset class characteristic 1. Report asset class characteristic 2 and asset class characteristic 3 on a best endeavours basis. 
  • Where the asset class sector type is, Equity (where the listing type is listed), an asset class characteristic 1, asset class characteristic 2 and asset class characteristic 3 on a best endeavours basis. 
  • Where the asset class sector type is Cash, Fixed Income or Alternatives, an RSE licensee must report asset class characteristic 1, asset class characteristic 2 and asset class characteristic 3. 

Refer to Appendix A: Asset class hierarchy in SRS 550.0 for the asset class characteristics which apply to each asset class sector type.

For each reporting period ending on or after 30 June 2023, an RSE licensee must report the information required under SRF 550.1. For each of these reporting periods, all asset class characteristics apply.

550.0 k: When should strategic sector and strategic subsector allocations be reported under SRS 550.0 table 1?

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.

550.0 l: How does APRA expect RSE licensees to report the target currency hedging ratio percent for strategic sector allocations where the domicile is ‘Not Specified’?

APRA expects RSE licensees to report the currency hedging ratio percent for strategic sector allocations where the domicile is ‘Not Specified’ in Table 1 of SRF 550.0 as the target currency hedging proportion for any internationally domiciled assets within that allocation. For example, for an allocation to the strategic sector of Equity, with the listing type of Listed and domicile of ‘Not Specified’, a currency hedging ratio of 50 percent would be interpreted as a target currency hedging ratio of 50 percent of those international domicile assets within the listed equity allocation.

550.0 m: When is the due date for RSE licensees to report information under SRF 550.0 for investment options underlying a MySuper product or trustee-directed product for reporting periods ending on or after 30 June 2021 but before 30 June 2022?

APRA expects RSE licensees to report information relating to investment options underlying a MySuper product or trustee-directed product, for the reporting periods ending on or after 30 September 2021 but before 30 June 2022, within 28 days after the end of the relevant reporting period in accordance with paragraph 12 of SRS 550.0.

APRA intends to revise footnote 6 when the reporting standard is next determined to read:

6 For the quarter ending 30 June 2021: due by the date in paragraphs 10, 11 or 18, as applicable. For the quarters ending 30 September 2021, 31 December 2021 and 31 March 2022: due by the date in paragraphs 12 or 18, as applicable. 

FAQs for SRS 605.0 

605.0 a: How frequently is reporting under SRS 605.0 required if there is no change to an RSE's products, investment menus and investment options?

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

605.0 b: What changes to products, investment menus, investment options or fee arrangements will result in an ad-hoc submission under SRS 605.0?
Superannuation products, investment menus and investment options:

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.

605.0 c: If RSEs are merging at 30 June 2021 what should they report under SRS 605.0? 

Reporting under SRS 605.0 is to reflect the structure as at 30 June each year. If there are structural changes that take effect on or before 30 June, APRA expects that reporting will reflect the new structure.

605.0 d: Can APRA clarify what should be reported under SRS 605.0 when the RSE does not have any superannuation products?

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.

605.0 e: Can APRA clarify what to report under SRS 605.0 when the RSE does not have an investment menu? 

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.

605.0 f: Should investment options that are not currently on offer be reported?

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.

605.0 g: Can APRA clarify what should be reported under SRS 605.0 and SRS 606.0 where the RSE offers MySuper as an investment option within one or more products?

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 this superannuation product 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 MySuper investment menu and option (using the same unique identifiers) in combination with the non-MySuper product on SRF 606.0. 

Where members in an investment option are not considered to have a MySuper interest, APRA expects that a different unique identifier is used for that investment option, even if the investment option has the same strategy as the MySuper investment option.

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

605.0 h: Which direct investment options can be reported on an aggregated basis?

Direct investment options that can be reported on an aggregated basis are direct shares, fixed income instruments or term deposits which have a common fee structure, investment option category and description in related disclosure material.

For example where there is an option for members to directly invest in individual shares on the ASX 300, this may be reported as one investment option with ‘Investment option name’ as ‘ASX 300 – individual shares’ for example, together with the number of shares either currently available to members or invested in by members previously under this option as ‘number of investment options’. Direct fixed income instruments and term deposits may also be reported collectively by duration and provider, for example ‘Bank X, 90 day’.

605.0 i:  Under SRS 605.0 are we able to re-use identifiers reported in the existing data collection under SRS 001.0 and SRS 700.0?  

Yes, for comparability purposes, APRA requests the use of existing identifiers where possible. 

Identifiers for select investment options, MySuper lifecycle stages and defined benefit sub-funds are currently reported under SRS 001.0. APRA requests that RSE licensees use the same identifier when reporting corresponding products, investment menus or investment options under SRS 605.0 where possible.

In the case of a single strategy MySuper products, APRA expects that the ‘MySuper Identifier’ reported in SRF 001.0 (Part D item 6(2)), would be reported as the; 

  • ‘Superannuation Product Identifier’ (SRF 605.0 (Table 1, column 2); and
     
  • ‘Investment Menu Identifier’ (SRF 605.0 (Table 2, column 2).

In the case of MySuper products with a LifeCycle strategy, APRA expects that the ‘MySuper Identifier’ reported in SRF 001.0 (Part D item 6(2)), would be reported as the:  

  • ‘Superannuation Product Identifier’ (SRF 605.0 (Table 1, column 2) and;
     
  • ‘Investment Menu Identifier’ (SRF 605.0 (Table 2, column 2).

APRA expects that the ‘LifeCycle Stage Identifier’ reported in SRF 001.0 (Part D item 6(2)) for each lifecycle stage would be used for each corresponding ‘Investment Option Identifier’ (SRF 605.0 (Table 3, column 2).

In the case of select investment options, APRA expects each ‘Select Investment Option Identifier’ reported in SRF 001.0 (Part E item 7(2)) would be used where possible for each corresponding ‘Investment Option Identifier’ (SRF 605.0 (Table 3, column 2)).

605.0 j: If a single member with a large balance has a negotiated a special fee arrangement (e.g. a discount to an administration fee), should this be reported as a separate fee arrangement in Table 4 of SRF 605.0?

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.

605.0 k: For legacy products that do not have a Product Disclosure Statement available to members, what should be reported in Table 1 of SRF 605.0?

Where a Product Disclosure Statement is not available to members, this field may be left blank.

605.0 l: For products that may have more than one Product Disclosure Statement available to members through a number of URLs, which URL should be reported in Table 1 of SRF 605.0? Or should the product be reported a number of times?

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.

605.0 m: Where individual members have differing advice fee arrangements with an advisor, are these considered to be separate fees and costs arrangements under SRF 605.0 Table 4?

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.

605.0 n: Does APRA expect the name of employers to be reported in table 4 of SRF 605.0? Can unique identifiers be reported instead so that the names of employers remain confidential?

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

605.0 o: Does APRA expect that the total of the ‘Member Assets Amount’ reported in SRF 606.0 will equal the total of member benefits reported in SRS 611.0?

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

605.0 p: Where members have differing fee arrangements within an RSE, are these considered to be a separate fee and cost arrangement under table 4 in SRF 605.0?

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.

605.0 q: How should trustee-directed products be reported in SRF 605.0 as at 30 June 2021?

APRA expects RSE licensees to report all investment options on table 3 of SRF 605.0 as at 30 June 2021. RSE licensees should report ‘Yes’ or ‘No’ in column 5 to indicate whether the investment option is a trustee-directed product. Submission of the 30 June 2021 period data for SRF 605.0 is due by 30 September 2021. If an RSE licensee reclassifies an investment option after the submission date, the RSE licensee should resubmit SRF 605.0 for the 30 June 2021 period with the corrected data in column 5. 

605.0 r: Where an inception date is unclear as there is a long history of the superannuation product what date does APRA expect to be reported?

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.  

FAQs for SRS 606.0 

606.0 a: How should we report the ‘Number of member accounts’ in an investment option underlying defined benefits? 

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). 

FAQs for SRS 611.0 

611.0 a: Are allocated pension products captured in reporting for SRS 611.0?

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

611.0 b: What value should be reported for ‘Member Benefit Bracket Type’ for annuity products?

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’.

611.0 c: How should defined benefit members’ benefits be reported in SRS 611.0?

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. 

FAQs for SRS 705.0

705.0 a: Do we need to report member initiated switching fees or buy/sell spreads on SRF 705.0?

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

705.0 b: Some components of net return (e.g. tax, performance fees) are not known on a quarterly basis and will not be known until year end.  How do we report these under  SRS 705.0?

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.    

705.0 c: Where all the components of the investment returns are not readily available as at the due date, how should the gross investment returns under SRS 705.0 and SRS 705.1 be reported? 

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.

FAQs for SRS 705.1

705.1 a: Where an investment option has multiple investment objectives, for example a CPI benchmark and a peer median benchmark how should this be reported?

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

705.1 b: The historical data collection for SRS 705.1 requires RSE licensees to report net investment return for periods where the prescribed breakdown of net investment return may not be available. For example for periods prior to 2014 administration fees may have been included in the net investment return and there is no available breakdown of the administration fee component. What does APRA expect RSE licensees to report for the net investment return for those periods?

For the periods prior to the introduction of the Stronger Super reforms on 30 June 2014, if data is not available to recalculate the net investment return as per the definition in SRS 705.1, RSE licensees should report the available net investment return which most closely represents the net investment return definition on SRS 705.1. 

For the calculation of volatility which includes periods ending on or before 30 June 2014, RSE licensees may take the same approach as for the net investment returns noting their input into calculating the ‘Volatility of comparison return (5 years)’ and ‘Volatility of comparison return (10 years)’ in SRS 705.1.

705.1 c: Where an RSE licensee currently calculates volatility using the standard deviation of daily returns, can APRA clarify expectations for RSE licensees to recalculate 5-year volatility and 10-year volatility for historical periods for all investment options, which will require recalculation of data going back to 2001 (where available)?

APRA intends to update the definitions for ‘Volatility of comparison return (5 years)’ and ‘Volatility of comparison return (10 years)’ in SRS 705.1 to allow RSE licensees to calculate the annualised standard deviation of daily returns for historical data. 

As described in FAQ 705.1b, for the calculation of volatility which includes periods ending on or before 30 June 2014, if data is not available to recalculate the net investment return as per the definition on SRS 705.1, RSE licensees may use the return which most closely represents the net investment return definition on SRS 705.1 as an input to the volatility calculation.

Therefore where an RSE licensee has an existing measure of 5 year and 10 year volatility, for example calculated as the standard deviation of daily investment return net of investment costs but inclusive of tax, RSE licensees may report this as the volatility measure for historical reporting (reporting periods ending before 30 June 2021). For ongoing reporting (periods ending on or after 30 June 2021), the volatility must be calculated as prescribed under SRS 101.0 Definitions for Superannuation data collections.

705.1 d: For some quarters, the Consumer Price Index (CPI) will not be released by the ABS prior to the reporting due date for SRS 705.1 Investment performance and objectives. When CPI for the quarter is not available, what should  be reported?

APRA  acknowledges this issue. The CPI release date will generally be prior to the due date. To allow industry sufficient time to prepare returns, APRA will update SRS 705.1 to allow up to 35 calendar days for the first year of reporting. 

APRA is considering potential structural solutions which may be implemented in a later phase of the SDT project to address this issue.

FAQs for SRS 706.0

706.0 a: How should fees and costs for defined benefit sub-funds be reported under SRS 706.0?

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

706.0 b: Some discounted fee structures exist for corporate superannuation plans that are not detailed in a PDS. Such arrangements may be subject to confidentiality clauses in contracts with employers. Are such fee structures required to be reported?

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

706.0 c: As buy/sell spreads can change regularly, do changes to buy/sell spreads trigger an ad hoc submission?

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

706.0 d: Should initial or ongoing advice fees that are individually negotiated between members and their financial advisers be included for reporting under SRF 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.

706.0 e: What is the frequency of reporting under SRS 706.0? Where a fee or cost is calculated or charged more frequently than annually, what reporting basis should an RSE licensee use when reporting the percentage or dollar charge?

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. 

706.0 f: How should RSE licensees report the fee cap for low account balances introduced under the Protecting Your Super (PYS) package of reforms? 

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. 

706.0 g: How does APRA expect fees and costs be reported under SRS 706.0? Gross of tax obligations or net of tax obligations?

APRA expects that all fees and costs reported under SRS 706.0 be reported ‘gross of tax obligations’ where ‘gross of tax obligations’ refers to gross of income tax, GST and stamp duty.  APRA intends to update SRS 706.0 to remove this reference: ‘consistent with the manner in which they are required to be disclosed in Product Disclosure Statements, where applicable’ when describing the requirement to report fees and costs gross of tax.

Worked Examples

 

A number of fictional entities have been created to describe reporting under the new reporting standards: 

Reissued 23 September 2021

Published 10 August 2021

Published 10 August 2021

Published 27 August 2021

Published 10 August 2021

APRA has made some minor updates to the SRS 251.0 Insurance worked example to correct alignment between the cover sheet and the data tables.

APRA has made an update to the ABC Superannuation worked example relating to data in SRS 706.0 Fees and Costs to clarify fees and costs reporting.