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Do you know what your super fund is invested in?

With trillions of dollars tied up in Australia’s super funds, you’d think it would be pretty easy to find out where all that money is invested. But that hasn’t always been the case.

Detailed information about the actual assets your super fund owns has been difficult to find, with many in the super industry arguing it was too complicated and expensive to provide. All that changed in March 2022, when new super regulations governing the disclosure of the holding within a super fund’s investment portfolio finally came into force.

Although there’s still room for improvement, some funds are actively embracing the new regime so their members can finally see exactly what assets their fund has purchased with their retirement savings.

Why knowing more about your super fund’s investments matters

Many super fund members are interested in seeing what assets their super fund invests in – it’s their money after all.

Greater disclosure is increasingly important as consumer attitudes towards responsible investing have changed. These days members are often keen to know their super is invested in line with their personal values.

According to the Responsible Investment Association Australasia’s (RIAA) 2022 report From Values to Riches, 74% of Aussies would consider moving to another provider if they found out their current super fund was investing in companies engaged in activities not consistent with their values. This is especially true for Gen Z and Millennial fund members.

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In addition, 79% of Australians would like their super fund or investment provider to communicate the impacts their investment are having on the planet.

This growing interest is in line with the government’s aims for the new regulations, which were designed to encourage super fund members to get more involved in saving for their retirement, with better disclosure increasing the “amount and quality of information available to superannuation fund members, employers and other stakeholders”.

Improved disclosure of super funds’ investment assets is also designed to allow financial analysts and fund members to better assess the level of investment diversification and risk inherent in the way their super fund has constructed its investment portfolio.

If you’re concerned about particular social, environmental and governance issues, the new disclosure regime should provide more detailed information about your fund’s investment portfolio. Fund members concerned about carbon reduction, for example, will be able to assess if their super fund invests in companies that fail to take account of this issue in their business activities.

Better disclosure of your fund’s portfolio holdings will also help you decide whether you are happy for your retirement savings to be managed by your current super fund.

What is portfolio holdings disclosure (PHD)?

From 31 December 2021, large super funds are required to make detailed information about the holdings in their investment portfolio publicly available on their website within 90 days of the reporting day. 

This means super funds must publicly disclose their portfolio holdings every six months, with the first reporting deadline being 31 March 2022. 

Under the Corporations Amendment (Portfolio Holdings Disclosure) Regulations 2021, super funds must disclose their holdings on an item-by-item basis for each investment option in a prescribed table format.

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Background to the PHD regulations

The introduction of portfolio disclosure for super funds has a decade-long history, with the provisions first introduced way back in 2012.

Although the PHD rules were originally meant to come into effect in December 2013, they were delayed until July 2015. The start date was then pushed back to 2016, 2017, 2019 and 2020.

Right from the initial recommendation in 2010 for full disclosure of their investment assets, super funds have been concerned about the cost and difficulty involved in regularly making such disclosures, fearing full disclosure would add to administration costs and drive up the fees paid by fund members.

According to Treasury, super funds were particularly concerned about the costs involved in collecting data for assets they don’t own directly, but instead own through third parties such as investment managers and collective investment vehicles.

There has also been a reluctance by super funds to disclose detailed information about investments such as private equity deals, unlisted assets and commercial-in-confidence arrangements.

Read more about investing in infrastructure.

What must super funds disclose?

Under the PHD regime, every six months super funds are required to disclose on their websites updated information about the investment holdings in each of the investment options they offer their members.

The rules require a fund to disclose sufficient information to identify:

  • Each investment asset in all the investment options offered by the super fund
  • The value and the weighting or exposure of each investment asset
  • The total value and the weighting or exposure of all disclosable assets.

Members will be able to see how much of their retirement savings are being invested by their fund across a range of asset classes and derivatives, making it easier to compare super products.

The regulations require super funds to disclose sufficient information to enable people outside the fund to identify assets held by the fund. Unlisted assets and some derivatives, however, can be aggregated or bundled for each type of asset, rather than needing to be identified individually.

Super funds are not required to provide information about any investments in an investment option closed to new members for more than five years.

Investments in an asset held solely to support a defined benefit interest or an asset relating to certain kinds of life policy or investment account contracts also don’t need to be disclosed.

Does my super fund need to disclose all it’s investments?

One of our members asked this question in one of our member’s Q&A webinars.

Q: Aware Super Fund told me that they do not disclose the products the super is invested in nor the quantity of units, but I have been told that this is incorrect and that they should disclose all these investment company names and the number of units that I hold in them?

A: Okay, I need to make a real disclosure here first. You need to get fund information directly from the fund. If you’ve received the response as a response, as the question suggests that you’re not happy with or you don’t think it’s right, go back and ask for a more senior person. The information that you’re asking for isn’t information, of course, that we can provide, and I’m sure you know that.

But what I did is I just jumped to the Aware Super site and had a look at the information which I could find on the website. When I look at the member statement, it would certainly show you which investment funds your super balance has been invested in, what you’ve chosen as your asset allocation or what you’re invested in through those investment funds. You’ll see on the snapshot there, it’ll say on your member statement lists each of those investment funds. Then I jumped on to the website, and it does give a detailed view of each of the investment funds and the data. Once you click on that file, you’ll see there I’ve just chosen the high growth fund there.

You’ll see if you click on that, there is an Excel file, it gives all the assets of the high growth fund. It lists the investments, the shares that it’s invested in, the bank accounts that it has, the term deposits that it has. It has all of the assets, the value of each of those assets, and how much each of those assets makes up of the fund, so the fund weighting. I found that on the website. It wasn’t difficult to find there. If you just jump on, I think you’ll see that information is available. Not sure what Aware Super was responding to, or maybe they got confused with the question, but I found that information on the website. Jump on there and have a look.

More work to be done on PHD reporting

Unfortunately, as super funds must use a prescribed table format for their PHD information, they are currently not obliged to provide their data in a simple-to-understand format, or one that can easily be used to compare the holdings of different funds.

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So far, if you’re interested in knowing a lot of detail about the individual assets included in your particular investment option, you’re likely to find yourself poring through huge spreadsheets listing thousands of line items. 

Some funds are trying to provide their information in a more user-friendly format with search and filter options, but as yet this is not occurring across the board.

One fund taking a lead in this area is Active Super, which has created an online data visualisation tool allowing fund members to click to see where and how the fund is investing their super savings. The tool allows members to see the identity, value and weighting of their investments across a range of asset classes and derivates, including unlisted assets.

Users can drill down from either an asset class or regional level to sector-specific industries and companies. They can also see how Active Super voted at the annual general meetings of the companies in which it invests. Data is also being updated monthly, rather than every six months as required.

Need to know

Following release of the first PHD reports by super funds in March 2022, the Australian Securities and Investments Commission (ASIC) reviewed a sample of PHD disclosures. It found most funds complied with their regulatory requirements, but there was “considerable room for improvement in the presentation of the disclosures”.

ASIC found improvements were necessary in areas such as the accessibility of the PHD information, consistency of reporting using the prescribed tables, and the clarity and readability of the disclosure information provided by super funds.

The regulator expects funds to focus on improving their portfolio holdings disclosure information in subsequent reporting periods.

Portfolio disclosure: Another way to compare super funds?

Despite these teething problems, if you’re trying to compare your super fund’s investment options, check whether it is investing in line with your personal values, or thinking about switching funds, your fund’s PHD disclosures are still an important source of information.

Given the detailed nature of the investment information super funds are required to provide, it’s likely specialist financial analysts and super ratings agencies will be the biggest users of the information rather than individual members.

Analysts and ratings agencies will use this new itemised information to learn more about the assets in each fund’s investment options. Hopefully, this will lead to the development of simpler, more easily understandable versions of the information fund members can use.

Activist groups interested in specific issues such as fossil fuel mining, corporate governance and labour standards will also dig into the new, detailed PHD information. Full disclosure of investment assets held by super funds will allow these groups to pinpoint the key shareholders and part owners in controversial businesses and they are likely to put pressure on super funds to lower or abandon any investments in these types of assets.

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