14 March 2003
Mr Lyndon Kingston
Senior Accounting Specialist
Policy Development
Australian Prudential Regulation Authority
GPO Box 9836
SYDNEY NSW 2001
Dear Mr Kingston
CPA Australia and the Institute of Chartered Accountants in Australia (ICAA) welcomes the opportunity to provide comments to the Australian Prudential Regulation Authority on the proposed superannuation reporting framework.
We understand that we will have the opportunity to provide further comments on the revised forms in the second round of consultation. This submission has been prepared in consultation with by CPA Australia's Superannuation Centre of Excellence and the ICAA's National Superannuation Committee
The ICAA and CPA Australia welcome the improvement of the reporting framework governing APRA regulated superannuation funds. We consider that the overhaul of the current regime will assist APRA, as better information will be provided to enable APRA to detect problems at an early stage.
Our submission will provide our general feedback (Attachment A) and will cover the following areas:
- Costs
- Timing
- Accounting Standards
- APRA and ASIC consultation
- Structure
- Guidance
- Audit Report
Attachment B covers our more specific technical comments.
Attachment C provides a timeline outlining APRA's proposal and the ICAA/CPA Australia's alternative proposal.
Should you have any queries or require further information please contact CPA Australia's Superannuation Policy Adviser, Ms Jane Barrett on +61 3 9606 9656 or by email: jane.barrett@cpaaustralia.com.au or ICAA Superannuation Technical Consultant, Ms Susan Orchard on +61 3 9502 4371 or by email: susanorch@optushome.com.au.
Yours sincerely
Jim Dixon
Director, Accounting and Audit
CPA Australia
Richard Rassi
Chairman National Superannuation Committee
