Submission – Proposed relief for disclosure of private debt arrangements

SMC supports the policy intent underpinning ASIC’s proposed relief for portfolio holdings disclosure and agrees greater aggregation is appropriate to address confidentiality and commercial sensitivity concerns. While the proposed approach falls short of fully addressing the legal, commercial and competitive risks associated with private credit disclosure, it is an improvement on the current requirements. The proposed approach reduces some of the more acute issues arising from asset-by-asset disclosure and represents a modest step towards a more proportionate framework by lessening the immediate risk of exposing transaction level details in concentrated private credit portfolios. SMC continues to call for a more effective and long-term approach which would mirror the treatment adopted for derivatives. This would remove borrower or counterparty names entirely for private credit assets and instead require aggregated disclosure supported by standardised, non‑identifying descriptors. By doing this, ASIC can better achieve its objective of maintaining meaningful transparency without exposing commercially sensitive information or creating unintended harm to members’ long-term investment outcomes. This would better balance member transparency with the need to protect commercially sensitive information and avoid unintended harm to Australians’ super savings.