We have submitted recommendations to APRA regarding the draft Prudential Practice Guide SPG 530. Our submission focuses on the importance of clarity and consistency in investment governance, stress testing, valuation governance, member equity considerations, due diligence, ESG impacts, and periodic reviews.
We recommend aligning stress testing frequency with the prudential standard, providing guidance on valuation governance for different investment types, reconsidering the necessity of a Valuation Committee, and addressing concerns about blackout periods and conflicts of interest.
