CA ANZ and CPA Australia generally support the measures contained in the reforms – with the exception of the best financial interests’ duty – it was our opinion that the reforms required significant adjustment to be suitable for the purposes for which they were designed.

Our submission raises points in relation to the performance including:

• 10-year lookback period
• Table of covered asset classes
• Trustee notification to beneficiaries
• Meaning of representative administration fees and expenses
• Performance test benchmarking
• The inclusion of pension and defined benefit products