Advocacy
FINSIA plays a unique role in advocating on major challenges facing the industry through regular submissions made on behalf of our members. Our advocacy efforts reflect the significant challenges confronting the financial services sector.
FINSIA SUBMISSION IN RESPONSE TO THE REGULATOR AND TRANSITIONAL RULES IN FINANCIAL ACCOUNTABILITY REGIME (FAR) REGISTER
FINSIA’s response considers the ‘key functions’ set out in the draft Regulator Rules as part of the materials concerning the proposed Financial Accountability Regime, released by APRA and ASIC on 20 July 2023 (and further explained in the accompanying materials).
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FINSIA SUBMISSION LEGISLATING THE OBJECTIVE OF SUPER
FINSIA believes there are practical benefits of legislating an objective for the superannuation system including providing certainty for individuals when saving for their retirement and improving the direction to trustees in respect of their duties in governing superannuation funds. FINSIA supports an objective that includes a purpose around equity. This will help ensure that further changes to the superannuation (and retirement income) system will support disadvantaged and less represented groups to maximise their superannuation (or retirement income) benefits.
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FINSIA SUBMISSION CLIMATE RELATED FINANCIAL DISCLOSURES
Given the global nature of business in Australia, it is important to align our climate reporting requirements with international practice on climate related financial disclosure. Any obligations for climate related financial disclosures that are developed in Australia should align with the reporting requirements currently under development by the International Sustainability Standards Board (ISSB) when they become available for jurisdictional adoption.
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AUSTRALIAN SECURITIES AND INVESTMENTS COMMISSION (ASIC) INDUSTRY FUNDING MODEL (IFM)
Broadly speaking, FINSIA agrees that it is appropriate to review the IFM at this point, given it has been in place since 2017.
While it is our opinion that the current model which ensures ASIC’s regulatory activities are paid for by those creating the need for regulation rather than taxpayers is appropriate and should continue, it is also our view that aspects of the current system need to be reviewed.
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FINSIA SUBMISSION TO QOAR PROPOSALS FOR REFORM
Broadly speaking, FINSIA is supportive of the direction in which the proposals are moving as part of this Review. It is essential, in our opinion, that the Review continue to reflect on the current design of the policy and regulatory framework that surrounds financial advice in Australia, and to advance recommendations for reform that will deliver to consumers more affordable and accessible financial advice. In our opinion, the full suite of recommendations put forward in the Proposals Paper should, on balance, deliver to consumers wider access and improved affordability of financial advice.
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FINSIA SUBMISSION TO RBNZ
In our view, the paper appropriately captures the central issue relating to the under representation of access to Capital for Māori, and also the relative percentages by which that under-representation is evident. The paper also captures the problem of securitising small size assets that Māori own. One observation is that the paper misses the history of why Māori are under-represented in the business space. In our view, this was driven by a 40-year government strategy (post WW2 to the 1980s) that has, in essence, subsidised Māori to move from country provinces into the metropolitan areas for (typically) low-skilled employment opportunities. This strategy was underpinned with low-cost housing through the state, which ultimately meant that Māori did not have the property asset base to loan against when they went into businesses later in their working life.
