Since 2013 the superannuation industry has been working to implement the Data and Payment Standards (SuperStream). These standards are now the “business-as-usual” operating model for rollovers for all APRA-regulated funds and for contributions for all APRA-regulated funds, SMSFs and large employers. Small employers should mostly all be on board by 1 July 2016.
Background
Since 2013 the superannuation industry has been working to implement the Data and Payment Standards (SuperStream). These standards are now the “business-as-usual” operating model for rollovers for all APRA-regulated funds and for contributions for all APRA-regulated funds, SMSFs and large employers. Small employers should mostly all be on board by 1 July 2016.
As a result of the implementation design of SuperStream, a commercial and technical network of providers who route the data for all these transactions on behalf of APRA funds and Employers has been developed. These providers, known as gateway operators and collectively the Superannuation Transaction Network (STN), now support an annualised projection of 75 million contributions and rollovers, representing $50 billion worth of transactions. Good governance of this network is vital to maintain the integrity and security of the network so that super funds and employers can continue to meet their legal requirements.
The FSC and four other industry associations have collaborated together with representatives from the Gateways over the last nine months to develop and agree a Business Plan to establish a new Gateway Network Governance Body (GNGB) to provide governance oversight of the STN of gateway operators. The Business Plan has been endorsed by all sponsoring associations, gateways and the ATO. This will enable the transition from a set of interim, government sponsored arrangements under the stewardship of the ATO, towards a more enduring and sustainable governance framework run and funded by industry.
What is the GNGB?
The GNGB will be a not-for-profit company, limited by guarantee, and co-sponsored by the above associations, whose purpose is to manage the integrity of the STN. Its members are the co-sponsors and each of the gateways operating at the time of incorporation later this year. Processes have been established to have new gateways enter the GNGB as they commence operating. There is no direct Government oversight of the GNGB however both the Australian Taxation Office (ATO) and the Australian Prudential Regulation Authority (APRA) will be engaged through an active stakeholder engagement framework, including as an observer in Board meetings.
The GNGB will have responsibility for initiatives or activity to promote the efficiency, effectiveness and security of the network, to engage with the industry and regulators on gateway matters, to manage compliance with the MoU and Gateway Standards, and seek for continuous improvement of the network. As such, it provides a bridge across the current “regulatory gap” in the SuperStream network.
The ATO are funding the establishment and first two years of operation of the GNGB. It is proposed that 85% of funding is to be sourced via the APRA supervisory levy. This effectively continues the existing SuperStream cost recovery arrangement (expiring in 2018) for this amount. We are optimistic that this will be supported by Government, and provide the primary funding model for 2018 and beyond. Gateways would contribute the remaining 15% of the funding.
What next?
I am now working with the Co-Sponsor members, gateways and the ATO to finalise the design and preparation for setting up the GNGB as a company. Current focus is on finalising the Constitution and redrafted Memorandum of Understanding, engaging the ACCC to provide authorisation on any aspects which may be affected by competition laws, and consideration of the composition of the Board and other key roles. This is a period of high activity, with plans to incorporate in the next few months.
The GNGB will be recruiting for both an Independent Chair and an Executive Officer, which will be advertised shortly.