Our submission to ASIC on its Cost Recovery Implementation Statement (CRIS) 2021-22 for comment calls for change in the process and the content.
We iterate our key concerns, already expressed in many conversations and submissions over the past few years, that:
- the release of the draft CRIS near to or after the end of the financial year to which it relates defeats the aim of the CRIS which is to help ASIC’s regulated population plan and budget for levies so
We seek for a draft CRIS to be released in the first month of a new financial year.
- the estimates provided are not indicative of the actual levy that will be charged further diminishing the value of a CRIS so, using the levies for our registered auditors as an example,
We seek for the estimates to be realistic and, where they vary significantly from the previous financial year’s levy, an explanation provided.
- where there is a significant change between the estimated and the actual levy no explanation is provided so, using changes across activities for our registered liquidators,
We seek for the final CRIS to provide detailed explanations for each sub-sector where actual costs allocated across activities change significantly from estimates.
- the release of a draft CRIS and a final version does not constitute genuine consultation as the estimates and commentary provided in the draft are replicated in the final CRIS so,
We seek for the draft CRIS to contain realistic estimates and the final CRIS to contain actual costs incurred for each sub-sector and detailed explanations of significant changes from estimates.
- there are inconsistencies between fees for service for activities undertaken by the same population. We highlight the fees charged by ASIC to prospective self-managed superannuation funds (SMSF) auditors to register and cease registration being unreasonably high and consider that they are distorting the market.
We conclude that for ASIC to maintain, facilitate and improve Australia’s financial system it must be transparent with, and accountable to, its regulated population. That regulated population seeks transparency through estimates of levies being provided in the first month of a financial year and actual levies detailed across activities for each subsector in the final CRIS.
Thank you to our members for their feedback which informed this submission.
Submission on ASIC assessment
In the submission to the Financial Regulator, we highlight the discrepancy between ASIC forecasts and actuals which undermines ASICs ability to be effective.Read more