OPINION PIECE - by Bianca Richardson, Senior Policy Manager – Investments and Global Markets and Vincent So, Policy Manager, Investments and Global Markets


In addition to changing operating environments, financial markets have also been subject to volatility and concerns regarding the COVID-19 impact. As your member organisation, one of the key areas where we have been able to assist members is to provide a direct line of communication to a wide range of regulators and key stakeholders. This has allowed member firms to have a collective and unified voice on important issues and to share critical market insights so that policy makers and regulators understand the coalface issues - which enables them to work with us to provide relief, deferments and support where needed. It has been pleasing to see regulators respond to our requests for relief and waiver and confirm that non-time critical projects would be put on hold and priorities refocused in response to COVID-19.

In spite of the disruption, work on important policy issues is continuing. One of our key areas of focus has been the Design and Distribution Obligations (DDO) which is intended to commence in April 2021. As many of you know the new DDO regime which will introduce new obligations on financial product providers to design and develop products which meet the needs of consumers in their intended target market. The DDO regime introduces sweeping changes and new obligations on product issuers and distributors, requiring development of new processes and systems. We have been working with members to develop Target Market Determination templates and create efficiencies through the development of industry wide templates.

Members have been investing significant resources in anticipation of meeting DDO requirements and were extremely concerned about meeting the deadline, particularly with the disruption caused by COVID-19, so we were very pleased with the news late Friday that ASIC will defer the April 2021 commencement period by a further 6 months. The FSC has been engaging with Government, Treasury, ASIC and other key stakeholders to raise member's concerns about the ability to make the requisite system and process changes during the COVID-19 period, so the deferral is welcome.

The Significant Investor Visa (SIV) is another important focus for us. The SIV offers a four-year pathway to permanent residency for migrants willing to make complying investments totalling $5 million in areas of the Australian economy. The SIV, we believe, has an enhanced role in supporting the national agenda of rebuilding the Australian economy post COVID-19 as it assists in job creation and driving economic growth including in key areas of the economy that can find it difficult to obtain investment capital.

For example, SIV applicants are required to invest a significant portion of their funds into Australian venture capital or growth private equity funds that back-in start-up and small private companies; and also invest in eligible managed fund that invests in emerging companies. Vincent So, Policy Manager for Investments and Global Markets has been leading this work for the FSC, engaging with stakeholders to highlight the benefits and the economic case to retain the current SIV system whilst supporting integrity checks to strengthen the program. Ensuring the right policy settings for the SIV will help drive innovation and the commercialisation of Australian ideas. 


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