The Prudential Standards for Investment Governance (SPS 530), Insurance (SPS 250), Risk Management (SPS 220) and Conflicts of Interest (SPS 521) all require frameworks. And they require the licensee to ensure that the frameworks are subjected to a “comprehensive review by operationally independent, appropriately trained and competent persons at least ever three years”.
The Prudential Standards commenced on 1 July 2013, meaning that the first reviews are due by 1 July 2016. All affected licensees should now be planning for the reviews, if they have not already been completed.
It is far from clear what constitutes a “comprehensive review”, and APRA has not provided much guidance on the point. The relevant Prudential Standards state that the scope of the reviews must have regard to the size, business mix and complexity of the licensee’s operations, the extent of any change to those operations and any changes to the external environment in which the licensee operates.
In our view, a comprehensive review requires more than a review of the relevant frameworks on the face. The reviews should also determine whether the processes referred to in the frameworks are in place and are effective.
Greenfields works with its Network partner, ReliabilityHouse (a risk and compliance consultancy), to provide a comprehensive review service that covers the legal and operational aspects of your frameworks for the purposes of the Prudential Standards.