CA ANZ notes that the Government intends to proceed with this policy as it was an Australian Labor Party commitment during the recent Federal election campaign.

CA ANZ notes that there were several key items which we felt were missing from the exposure draft legislation, such as:

• A definition of ‘faith-based product’ which is not circular
• Details regarding how APRA should address any overly narrow investment strategies
• Guidelines for APRA in approving proposed indices to be used for benchmarking investment performance or determining alternative indices to be used in the event that APRA determines that the proposed index is not appropriate.

A further point we note is that APRA’s decisions would not be reviewable, meaning that if APRA made a mistake, the affected trustees would not be able to appeal this decision.