Consultation on Financial Resources for Risk Events in Superannuation: Operational Risk Financial Requirement
Submission Date: 13 May 2024
This submission has been prepared by the Superannuation Law Committee of the Law Council of Australia’s Legal Practice Section (the Committee).
The Committee welcomes the opportunity to make a submission to the Australian Prudential Regulation Authority (APRA) about the draft amendments to Prudential Standard SPS 114 – Financial Resources for Operational Risk (SPS 114) and Prudential Practice Guide SPG 114 – Operational Risk Financial Requirement (SPG 114).
The Committee acknowledges that registrable superannuation entities (RSE) licensees need to ensure they have ready access to financial resources to respond to, and rectify, the impacts of operational risks.
The Committee provided its response to APRA’s Discussion Paper – Strengthening Financial Resilience in Superannuation in its submission dated 18 March 2022.
The Committee notes that, having considered industry feedback, APRA will not progress the proposal to introduce separate components to the Operational Risk Financial Requirement (ORFR). Instead, APRA’s simpler approach is focused on integration with CPS 230 and better enabling use of the ORFR financial resources when needed.
Last Updated on 11/12/2025
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