Maintaining the integrity and objectivity of the Your Future, Your Super (YFYS) performance test is critical to achieving better outcomes for members, according to the Grattan Institute.
In its submission to the YFYS review, the think tank argued that the government should be seeking to make “incremental improvements” to the framework, rather than wholesale reforms.
To date, 10 out of the 13 funds that failed the inaugural YFYS performance test in 2021 have merged — or are in the process of doing so — while the other three have reduced their fees.
The Grattan Institute estimated that members of these funds are now paying fees that are around 20 per cent lower, representing a saving of more than $100 million.
“The objective nature of the test was critical to achieving these benefits and must be protected,” Brendan Coates and Joey Moloney of the Grattan Institute wrote in their submission.
“There is scope to refine and improve the test, and any changes that improve its operation without compromising its integrity should be welcomed. But the broad structure of the test must be retained.”
The think tank said that the expansion of the performance test to Choice products, which was delayed for 12 months in order to undertake the YFYS review, should go ahead.
Citing data from APRA’s first Choice heatmap late last year, which found that 60 per cent of products underperformed their benchmark with 25 per cent delivering very poor returns, the Grattan Institute said that Choice is where the highest fees and worst performance are.
The prospect of creating carve-outs for certain Choice products, it said, would be “bad policy” and would increase the risk of the test being “gamed”.
“Introducing subjectivity into the test — such as allowing APRA greater discretion in applying the test — would compromise its integrity and risk recent gains to super fund members,” Mr Coates and Mr Moloney added.
“Funds can always find an excuse for their underperformance or high fees, and regulatory risk aversion suggests this could lead to the policy being toothless.”
The expansion of the test should include investment options available via platforms and other more sophisticated channels, the Grattan Institute has suggested. It argued that excluding them may mean that some of the worst-performing choice products are left outside the YFYS regime.
While acknowledging that the complex nature of these options poses some challenges, the think tank said that complexity can also be used to “disguise high fees or poor performance”.
It also noted that an underperforming option via a platform may only represent a small portion of an individual’s overall portfolio, particularly if it is overseen by a financial adviser.
“A separate prescribed letter for Choice products in the regulations should reflect this,” said Mr Coates and Mr Moloney.
“The test and its consequences should still apply, as it will provide a benchmark for platform providers and advisers to consider what is being offered and recommended to clients.”
Among the suggestions put forward by the Grattan Institute, the think tank argued for the performance test time frame to be extended to 10 years from the current eight years, and for new asset classes to be added to the test where appropriate.
“The super industry would prefer to be left alone, or to have the opportunity to convince the regulator that they shouldn’t have to change,” Mr Coates and Mr Moloney said.
“But too many Australians have already suffered poor outcomes in superannuation for far too long. Maintaining the integrity of the Your Future, Your Super reforms will help ensure that won’t be the case in future.”
