While ASFA supports the proposed seven-day and 14-day requirements for updating certain matters, the industry body argued the same-day requirement for Product Disclosure Statements (PDSs), Financial Services Guides (FSGs), annual reports and annual financial statements was unrealistic.
ASIC stated in Consultation Paper 219: Keeping superannuation websites up to date that this was a reasonable timeframe, given that no further work is required other than converting the documents to a different format, which can be done before the documents are given to recipients.
ASFA policy director Fiona Galbraith argued that updating the website requires the appropriate staff to be available and that no technical “glitches” occur that could impede updating.
“There is always a risk that staff absences or technical issues will make it difficult or impossible to instantly update a website,” said Ms Galbraith.
ASFA believes updating PDSs and FGSs by the end of the next business day would be a more appropriate timeframe.
“While normal practice is likely to be that PDSs and FSGs are uploaded onto websites on the same day, stipulating this as a strict regulatory requirement is, in our view, too onerous,” Ms Galbraith said.
In terms of annual reports and annual financial statements, ASFA said the required time for updating should be extended to 14 days.
“Given that PDSs and FSGs are important documents, which consumers rely on to make investment decisions, websites should be updated virtually immediately,” she said. “This is not the case for annual reports and annual financial statements.”
Annual reports and annual financial statements should be treated in a similar way to the other documents referred to in regulation 2.38, she added.
