Superannuation Data Transformation Strategic Forum - 16 May 2023

APRA held the Superannuation Data Transformation (SDT) Strategic Forum (SDTSF) on 16 May 2023. The purpose of this forum is to contribute to the understanding and resolution of strategic issues arising throughout the implementation of SDT project. Hosted by Alison Bliss, the May SDTSF was attended by 18 industry stakeholders (see Appendix A for the full list of attendees).  

16 May SDTSF: Key discussion points 

Since the last forum, APRA released the SDT project roadmap and the notes from the February SDTSF. 

Alison Bliss provided an update on APRA’s new 'Technology and Data' division. Noting Alison’s change in role, this is her last forum as chair.  The governance and sponsorship of projects is under review, and the new chair will be confirmed in due course.   

APRA provided an update on recent activities under the SDT project: 

• APRA released a Minor Amendments response paper on 3 March 2023 which included removal of best endeavours for expenses and asset allocation, updates to reporting due dates and reduction of frequency of ad-hoc reporting. In preparation, APRA held several Asset Allocation and Expenses working groups and informal meetings with entities.  
   
• To support the Minor Amendments implementation, APRA held a webinar, and has released additional FAQs, including an updated reporting timetable. APRA will continue to engage with industry further on updated and new worked examples. 
   
• Industry requested further discussion about industry resourcing capacity in light of other deliverables​ and APRA provided an updated SDT project roadmap. 
   
• On Phase 2 collection development, APRA held workshops with industry working groups.  
   
• APRA noted they intend to continue informal industry engagement on proposals for collections under the topics of Investments and RSE Licensee and RSE Profile through to the end of June 2023, including further workshops on Valuations and Liquidity.  
   
• APRA will delay formal consultation on proposed reporting standards for investments and RSE Licensee and RSE profile until November 2023, incorporating a request from industry to avoid consultation on reporting proposals over the peak year-end reporting period.  
   
• APRA will communicate further updates on the SDT project on the APRA website. APRA welcomes feedback on the SDT project roadmap and will continue to engage with stakeholders to understand industry's capacity to engage in consultation and implementation under the roadmap and impacts to industry of any changes to timeframes.  

SDTSF members (“Members”) provided feedback requesting clarity of the impact of the delayed consultation on the project roadmap and whether APRA expects the delay to lead to two consultations in November or an overall delay in the program.  Members requested more line of sight on proposed changes to the project to enable better forward planning and cost management. Industry noted the difficulties in obtaining the right resources at the right time and the need to have stable 2-year view on the program to avoid loss of skilled / informed resources. 

Members also noted several items such as: 

• the recent announcement on payday super and how it will cause increased demand on industry capacity over the next three years. They also raised concern about the end of financial year timing.  
   
• interest in the Valuations and Liquidity workshops planned for the end of month. Members requested further detail to be provided in advance of industry workshops, to ensure the right subject matter experts are attending the right discussions. 
   
• discussion about the SPG 530 consultation / interface and alignment across prudential framework. APRA advised that they are working to ensure alignment between SPG 530 outcomes and data reporting.  
   
• Members asked APRA to provide an update on worked examples for profit reporting and whether this has been communicated. APRA confirmed that the intent to develop worked examples for 'profit reporting' in collaboration with industry has been referenced in Minor Amendments response paper, and the minor amendments webinar. 

APRA also provided an update on APRA Connect: 

• In March APRA made changes to improve the timing of submissions, work is continuing with the vendor to reduce the timing even further.  To continuously improve the submission process experience, APRA will send a survey to obtain feedback. 
   
• Another APRA Connect superannuation technical working group will be held, and invitations will be sent out next week.  
   
• APRA is working on an approach to communicate scheduled outages (APRA will provide advance notice (typically a week), with a confirmation email on production release date, and have a blackout period with no release within days of submissions).  
   
• For unscheduled outages such as the recent Australian Taxation Office (ATO) (MyGov) issue, APRA will display a banner containing relevant information to keep users informed of the status of the system.  
   
• Regarding the recent ATO [MyGov issue], APRA noted it was unable to gain any indication from ATO as to how long MyGov would be down. When the outage extended beyond a day, APRA provided an extension to submit to industry.  

Members shared that an issue with this approach was that trustees didn't know there was a problem until they had to lodge, and that proactive communications would be welcomed. Members suggested that the ATO model of providing updated communications every 4 hours in the case of an unplanned outage was helpful and good practice. APRA noted that they will consider how email communications could be utilised in these instances in the future. 

Industry discussion topics 

AIST presented an update on the development of a business case for a central industry reporting repository for external fund manager data. Industry sees the benefit in getting consistent data for listed products.  

Some stakeholders noted that there may be limited benefit for entities who have already developed reporting solutions, and therefore may have low appetite for rebuild. 

AIST and ASFA will discuss further the work undertaken to date and next steps. 

Members asked APRA about the engagement approach with Custodians. APRA confirmed that ACSA members are involved in relevant APRA working groups, and APRA has regular meetings with ACSA on implementation of reporting including input on worked examples. 

The next SDTSF will be held on Tuesday 8 August 2023 from 2:00-3:00pm. 

Appendix A – SDT Strategic Stakeholder Forum attendees