In our opinion, the consultation timeframe for this policy has been too short and should have been more open to improvements or other alternatives.

Our main comments centre around:

• the development of innovative retirement income stream products
• Types of splitting arrangements for innovative superannuation interests
• amendments to methods and factors to reflect current actuarial assumptions
• conditions of release and releasing events
• superannuation annuities – valuation and payment splitting
• unsplittable interests
• ensuring approved methods and factors are based on current actuarial assumptions