Submission – Proposed class exemption: Approval to own or control an RSE licensee

The Super Members Council (SMC) supports APRA’s proposed class exemption for management and company secretaries with small (<2%) holdings in RSE licensees, as it streamlines governance, reduces associated costs and ultimately maximises member returns. However, in light of recent regulatory action concerning the collapsed schemes Shield and First Guardian, SMC considers that the operation of this exemption may warrant further review at a later stage.

SMC recommends that the proposal be reviewed within a reasonable timeframe of two years. This timeframe would be sufficient for APRA to assess the effectiveness of the exemption and allow observation of real-world implementation. It also balances regulatory caution with burden reduction within timeframes that align with common post-implementation review practices.