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APRA COVID-19 Pandemic Data Collection

Tuesday, 21 July 2020   (0 Comments)
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In June, 2020 APRA wrote to Registrable Superannuation Entity (RSE) licensees (superannuation funds) informing them of new requirements intended to enable assessment of the impact of COVID-19 on the superannuation industry. See APRA PDC Letter.


While members of ACSA are not registrable superannuation entities, many ACSA members are engaged by RSEs to assist in meeting their regulatory reporting obligations.


Balancing Priorities


The letter says that “APRA understands that RSE licensees have been under considerable pressure during the COVID-19 pandemic, however APRA considers that the data in the PDC is essential to enable APRA to analyse the impact of COVID-19”. 


New reporting adds resourcing and change management overheads to RSEs – just at the time they are facing significant disruption and focused on their own specific operational challenges and dynamically changing environment.


Some observations on the practical impact of the PDC include:


Compressed and inconsistent due dates with other APRA data collections

  • The lodgment timelines are short.  Quarter-end and/or book close processes already place significant strain on resources within these time windows.
  • The first reporting period will be during financial year end (a busy time for all funds and their service partners).
  • Other (existing) comprehensive reporting obligation for RSE licensees are generally required within 28 calendar days after the end of the quarter, again creating resource contention.


New development required

  • New reporting requirements require the definition, extract, compilation, review and formatting of information by funds.
  • It is unlikely existing reporting processes will be able to be utilised to meet the data collection requirement (that is, new processes will need to be developed and tested).
  • Resources applied to new regulatory reporting requirements mean that other risk, member service or management information priorities of the RSE may be impacted.

ACSA Submission


ACSA has provided a submission to APRA with observation on the requirements and requested industry consultation when the PDC is reviewed in September.


A copy of the submission to APRA is available to Members on request to or via the ACSA Regulatory Working Group.




About the Australian Custodial Services Association (ACSA): The Australian Custodial Services Association (ACSA) is the peak industry body representing members of Australia’s custodial and investment administration sector. Our mission is to promote efficiency and international best practice for members, our clients and the market. ACSA works with peer associations, governments, regulators and other market participants on a pre-competitive basis to encourage standards, process consistency, market reform and operating efficiency. Established in 1994, ACSA members currently hold assets in excess of $4 trillion in custody and under administration for Australian institutions.


Important Note: The views expressed in this communique have been prepared by ACSA for the purposes of general information to Members   Comments do not comprise financial, legal or taxation advice and should not be regarded as the views of any particular member of ACSA.

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