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Super needs more rethinking outside the box

The COVID-19 pandemic, like the GFC before it, has forced the authorities to take actions unthinkable even for the most adventurous interventionists. Faced with an unseen predator able to jump across species and continents in our interconnected world, the varied global responses show the challenges in addressing its health, financial and social impact effectively.

Science – always imperfect and evolving – has few reliable pointers yet and many questions. Statistical approaches applied to large groups have little to reassure individuals exposed to the pandemic: the tyranny of averages.

The bold decisions announced by the Australian authorities splurging resources with rare multi-partisan support would be considered brave, indeed courageous in ‘Yes, Minister’ speak. But they are unavoidable.

What about some other super options

In super (our multi-trillion retirement savings vehicle propelled by compulsion and tax concessions and constrained by preservation), significant changes have been announced, including halving the minimum drawdown rates in pension phase, and allowing limited access up to $20,000 for those in dire need. The apparently opposite measures make sense, by reducing the pressure for fire-sales of assets locking in non-deductible capital losses, and by allowing strugglers to cope.

Retirement yonder only makes sense if the victimised savers survive till then.

As the Government has made it clear that the rapid-fire reforms are still work-in-progress, what more can or should be done?

It is useful to invoke the mantra super lawyers, regulators and consumer advocates intone all the time, ‘the best interest of members’, which can only be assessed with available incomplete information. By this definition, rushed super reform is not designed to benefit any other stakeholder including trustees, employers, service-providers, professional advisers or financial planners. They have all been caught up in the COVID-19 mess, but must do what it takes in members’ interest.

Calming the public, restoring confidence in markets and adjusting to the physical, emotional and financial pressures would make the task less difficult.

Here are a few:

  • To reduce the selling pressure, allow those with available cash in super to lock it in under preservation by relaxing concessional and non-concessional contribution limits – say double them with a minimum of $50,000 and $250,000 respectively per financial year. This would enable those currently unable (pensioners who have reached the transfer balance cap, those above age 75 etc) to contribute to their nest egg.
  • Clarify that those who have already withdrawn more than the reduced minimum rates in 2019/20 can repay the excess if they are able. This would treat them on par with those who have not yet drawn more than the current minima, to preserve equity and fairness.
  • Consider increasing the $1.6 million cap on pension balances given the extraordinary reduction in balances. This is despite the clear current rules which prevent topping up due to market falls (and symmetrically, having to reduce in a boom) and goes to the substance of confidence rather than literal compliance.
  • Allow companies to distribute franking credits even without any dividends being paid. This is largely a book-keeping adjustment over time, but would increase confidence shaken by valuation losses, as more companies find they are unable to pay dividends and some funds are beset with illiquidity.
  • Facilitate liquidity for funds forced to fire-sell to meet the improved access. Despite the haranguing about ‘they should have seen it coming’, nobody foresaw how a wet-market disaster in China would make the world wet their foundation garments. Hindsight is wonderful but not available at the ophthalmological dispensary. Silly to let the emergency measure to sink those caught up, especially if they have sensibly matched long-term liabilities with illiquid liabilities given increasing longevity. Hit by a crisis of confidence, illiquid assets freeze (as occurred during the GFC, and APRA was forced to reprieve funds unable to pay).
  • Clarify super funds can access the small business grant of between $20,000 and $100,000 subject to the announced turnover limits. This is not the time to quibble if SMSFs can run a business (ATO says they can, subject to qualifications). The fact is like any other managed investment scheme, they are a business in themselves buying and selling assets to make revenue and capital profits. No amount of semantics could alter this reality. Note these funds constitute the engine-room which support many small businesses comprising outsourced service-providers as well as audit, accounting and actuarial professionals.

No doubt this is a laundry list, but we should debate the ideas as the outlook is decidedly uncertain.


Ramani Venkatramani is an ex-APRA regulator, now the Principal of Ramani Consulting Pty Ltd. He advises on risk, regulation and retirement outcomes and trains global regulators in supra-national core principles of banking, insurance and pensions supervision, crisis pre-emption and remediation.


Reader comment
April 19, 2020

Who would want to be a Treasurer or PM. You are trying to increase government revenues in a period of high unemployment, when national wealth and incomes are down, property prices may have dropped or stagnated and community moral is low. Increased GST is broad based but requires agreement from all states, primarily benefits the States, if extended to food products will impact low income earners and will fuel inflation possibly leading to interest rate rises. The grey army is loading the cannons for any future grabs at our franking credits and super incomes. Property prices may be down or stagnant, tourist rental incomes have taken a major hit; rental incomes have been savaged and evictions denied and with interest rates at all times low (only one direction from here) so property investors are wary unless they can find a bargain. Conclusion - removing negative gearing would adversely affect property prices and hence rental availability and affordability. The government has recently simplified and reduced personal and company taxes with more to come. Further simplification but at higher rates would seem to be the best option. High income earners spend less of their after-tax income so support the economy less than the lower income families. As for company taxes we need to stay competitive so other countries would need to increase company taxes so Australia to adopt this as a revenue raiser.

April 19, 2020

' Nobody foresaw how a wet-market disaster in China would make the world wet their foundation garments. Hindsight is wonderful but not available at the opthamological dispensary''. I have been reading information from October 2018 that indicates the risk reward in US market was historically very high (historically high P.E), outflow to bonds (resulting in lower rates and increase in bond value of bond funds. For the those at or nearing retirement, I thought it would have been prudent, to take some of the table, that is switch portfolio to defensive Maybe the warm fussy feeling from doing that would, alleviate some of the warm fuzzy from the roller coaster ride

David M
April 16, 2020

Are you serious? Relaxation of contribution limits is a more broader discussion - however I cannot see any clients great rush to make non concessional contributions. As for concessional contributions being increased, this comes back to the argument around fairness in our tax system - and shouldn't be thrown into the conversation around crisis management. How about we talk about the elephant in the room, the ridiculous allocation made to illiquid investments by some industry super funds who never imagined the day that the cash cow of SG contributions could turn the other way. This obsession of illiquidity premia without any thought to the potential illiquidity cost. And where was APRA? Asleep as usual. If a regulator is asleep in the woods and no one sees it , does it even exist?

April 16, 2020

Thanks David. The ideas are for debate as was made clear. I am glad you are engaged.
Given hindsight is available only with hindsight, we have to rely on past crises to sign-post possible steps (no gurantees). They show that remarkable recovery follows (e.g, GFC) despite rach crisis being different.
The two seemingly contrary super stimuli show the need to help strugglers (preservation diluted) and preserve pension balances (drawdown halved). Horses for courses. On this basis, if people with spare cash and suitable risk tolerances with to dollar cost average their entry back into super, relaxing contribution restrictions would help by increasing the demand for securities.
Obviously you know your clients best.
As for liquidity management in super, you make fair comment, but with hindsight. Had COVID-19 not happened, the relentless rise of markets would have caught excess cash-holders flat-footed. And if APRA had intervened and adversely affected member outcomes (after bravely venturing into this space in our DC regime where planners and members can and do choose), they would not be thanked either. APRA is no Nostradamus.


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