VOLUME 34 - ISSUE 5, NOVEMBER 2020

Page 14

SUPER PERFORMANCE TEST

Super changes will undermine innovation, nation building and member returns BY MATTHEW GRIFFITH

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The Government’s proposed superannuation performance test could drive the market towards an oligopoly structure which could create diseconomies of scale and concentration risk.

Australia’s superannuation system has been reshaped over the past two decades by market forces and regulatory reform, creating an industry that has significantly consolidated and is widely acknowledged globally as a strong system. We all want to strive for better member outcomes and while the Government’s superannuation budget initiatives are generally in the right direction, one proposal, whilst well-meaning, appears interventionist and flawed. Subjecting super funds to an annual performance test – creating a ‘league table’ index and blocking underperformers from taking new members – is overly simplistic and will have potentially significant, negative impacts on investment outcomes for members. I fear that the drive to be within 0.5% of a simplistic portfolio benchmark test as proposed by the Government, with harsh consequences for failure,

will incentivise a focus on simply being average, rather than being great. This flies counter to my 20 years’ experience in the industry which has witnessed diverse approaches to objective attainment, including funds “bucking the trend” by early adoption of investments in unlisted infrastructure and property, internalisation, backing start-up managers and entrepreneurs through investing in private equity. We take many of these innovations as industry norms today, but at the time when these were adopted, they were innovative and required courage to take a carefully calculated risk. Many of these approaches have been enormously beneficial to members. Instead, the Government’s proposed benchmark test has potential for less innovation, amongst other consequences detrimental to super fund members. Firstly, trustees may become significantly more index aware, resulting in asset

allocation and investment approaches based significantly on an index and peers, rather than investment opportunities that are considered in the best interests of members. Secondly, trustees may become more fee conscious, resulting in approaches that limit access to high potential return but higher cost investment opportunities that would be expected to improve returns and/or reduce risk (e.g. including nation building infrastructure, property, and support for entrepreneurs through private equity and small public companies). Thirdly, we could see trustees being less prepared to adopt longer term investment approaches better suited to the long-term nature of superannuation for fear of failure of not meeting the performance test. Fourthly, market behaviour might actually continue to focus on shorter term measures, resulting in net cash outflows from some very high quality, strong long-term performing funds that have

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