ASIC Consultation Paper 203 - Age Pension Estimates in Superannuation Forecasts: Update to RG 229

Submission Date: 19 April 2013

The Law Council supports the refinement of Regulatory Guide 229.¹

The Law Council broadly supports the proposed provision for trustees to include the age pension in benefit projections, on an optional basis.

The Law Council is not making a submission on all of the questions posed in Consultation Paper 203.² The comments focus on technical issues rather than policy matters.

In summary, the Law Council's comments are:

• The requirement for age pension estimates to include an assumption that the member has a partner requires clarification in relation to the assumed income and assets of that partner. Alternatively the requirement could be that the estimate assumes the member is single.
• A projection that includes the age pension should be required to include an explanation of the assumptions used in identifying the pension amount.
• Projections should be able to use a default retirement age if the Fund does not have the member’s date of birth.
• The circumstances in which ASIC will adopt a ‘no action’ position, where the trustee adopts the methodology provided in RG 229 and the Class Order, require clarification.
• The calculation of administrative fees for the purposes of projections should be expressed to exclude ad hoc fees of an incidental nature.
• The refinements proposed in the Consultation Paper may not necessarily result in more trustees providing retirement projections to their members.
• The Law Council suggests that ASIC consider additional refinements. Some examples are:
  • allowing more realistic assumptions about contribution rates; and
  • allowing trustees to incorporate by reference the prescribed text in relation to warnings and assumptions.

^{1 Australian Securities and Investment Commission, Regulatory Guide 229: Superannuation Forecasts (2011).
2 Australian Securities and Investment Commission, Age pension estimates in superannuation forecasts: Update to RG 229 (2013).}

Last Updated on 27/05/2025

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