The requirements call for a trustee to publish the latest product dashboard for an investment option in the periodic statement in relation to reporting periods ending on or after 31 December 2013.
However, the FSC pointed out that a member who has exited from the product does not need the information contained in a product dashboard.
“Therefore, providing the information is unnecessary and the cost of producing this information is a waste,” FSC senior policy manager Andrew Bragg wrote in the group’s submission to Treasury.
The FSC also pointed to the “enormous” IT changes that would be required and said it would take well over the six month lead times the industry had to work with to implement.
“The last minute requirement that both MySuper and Choice Product Dashboards be added on to Periodic (both annual and exit) Statements will not increase member understanding and will result in increased administrative cost and complexity,” the FSC argued.
It would also be useful for the Government to clarify that for a lifecycle MySuper product; only the dashboard for the relevant cohort needs to be sent to the member, the FSC stated.
Mr Bragg also said the industry is “very concerned” about the consultative process by which the measure was brought in.
“This requirement was never contemplated throughout the Cooper Review, nor actively pursued in the Stronger Super consultation period. As a result we remain opposed to this requirement,” the submission stated.
The FSC called for “comprehensive consumer testing” of the different periodic statements to establish if there is any benefit including the most recent dashboard on the back of periodic statements.
The measure will require capital intensive upgrades, sophisticated data matching technology of a member’s options, with prohibitive development costs across the industry and long lead times to develop and implement, according to the FSC.
This will lead to increased on-going costs for members, increased paper usage and the associated environmental impacts, the FSC argued.
“The measure is duplicative, increases administrative costs and is unnecessary. In our view, it cannot be justified on any cost/benefit analysis and will simply result in the industry producing millions of additional pages of paper based disclosure to members each year,” the submission said.
