This form must be completed on an annual basis by all trustees of APRA-regulated superannuation entities excluding Small APRA Funds (SAFs) and Single Member Approved Deposit Funds (SMADFs).
This form can be left blank as D2A recognises blanks as zeros; however it is still required to be submitted as part of the annual return. Trustees of superannuation entities, holding Investments in PSTs that have a value of more than 5% of total assets, are required to report on SRF 220.0 Exposure Concentrations.
(Trustees of those superannuation entities with total assets of at least $50m at the end of the most recent year of income of the entity that are required to complete SRF 120.0 Exposure Concentrations on a quarterly basis must also complete this form on an annual basis.)
Note: All forms included in the SRF 200 series should be submitted together as an annual return, not individually as separate forms.
Purpose
The large exposure form is required by APRA for the provision of information on concentrations in exposure of a superannuation entity. For example, regarding the performance of a particular investment held by a superannuation entity, or a counterparty to which the superannuation entity has an exposure/investment with (i.e. moneys invested at call).
Exposures are only required to be reported in this form where the exposure is greater than 5% of the net market value of total assets of the superannuation entity, as reported in SRF 210.0 Statement of Financial Position under item 5 ‘Total assets’. If there are more than 10 such exposures, only the largest 10 are required to be reported on this form. (Note: All exposures, whether of an asset or liability nature per item 1 of this form, are to be determined with reference to 5% of total assets).
Information reported in this form is prudentially important, as it forms part of APRA’s monitoring and analysis framework for a superannuation entity and the superannuation industry.
This Guide has been prepared to assist in the completion and lodgement of SRF 220.0 Exposure Concentrations. For ease of use, the Guide has been split into three main sections as follows:
Lodgement and validation of and changes to SRF 220.0 Exposure Concentrations;
General guidance – this guidance provides principles that should be applied to all items throughout SRF 220.0 Exposure Concentrations; and
Instruction guide for specific items – this guidance should be applied to the specific items which relate to each superannuation entity.
Lodgement and validation of SRF 220.0 Exposure Concentrations
Lodgement and authentication codes
This form must be completed and lodged to APRA by a corporate or natural ‘person’ (trustee director or administrator), and not by the superannuation entity as the entity is not a ‘person’.
Once SRF 220.0 Exposure Concentrations has been completed and submitted to APRA, an authentication code is generated in D2A from information entered into the form. The authentication code and date submitted appear in the footer of each page of the return (‘return’ equates to all 9 forms). Any change of information entered or resubmission of the return will result in a change to the authentication code. The authentication codes and date submitted should be used by auditors to determine that the four forms audited (SRF 200.0 Statement of Financial Performance, SRF 210.0 Statement of Financial Position, SRF 220.0 Exposure Concentrations and SRF 230.0 Transactions with Related Parties) have been submitted.
The same authentication code on all the forms lodged will give trustees some 'comfort' that their attestations on SRF 260.0 Trustee Statement relate to the other forms submitted as the return. Different authentication codes should be taken by trustees that their attestations are not consistent with other forms and APRA may take the view that the return has therefore not been signed and authorised by the trustee.
A receipt indicating successful lodgement of the return will be provided via email. There may be a slight delay in a receipt being provided if the submission is made in the last week of October. Do not resubmit your return however, as the receipt will be generated.
Validation and calculation of totals
When data is entered into the form, the total balances (in the greyed out cells) will not be calculated automatically. The total items will only calculate when the form is validated. Clicking on the word 'validate' in the top left hand corner of the screen and selecting ‘OK’ will result in the total items being calculated and the validation rules appearing for review.
There are three types of validation rules as follows:
Warnings: Confirmation rules – this rule requires the user to provide confirmation that the data entered into an item is correct, for example that a negative number is correct and should not be positive. To provide confirmation the user should click the confirm box and provide a brief description in support of the item.
Note: Descriptions entered for warnings may not always appear if the return is validated more than once. There is no need to re-enter the description as D2A has saved this description and the comments will be lodged with the return.
Error: Mandatory rules – this indicates an error in an item, for example a description and a value must be included in a table. These errors must be corrected before the return can be lodged.
Cross form validations – this also indicates an error and must be corrected before the return can be lodged, for example Totals disclosed in SRF 210.1 Selected Disclosure of Investments must agree with the investments reported in item 3 ‘Investments’ on SRF 210.0 Statement of Financial Position.
Changes to SRF 220.0 Exposure Concentrations
As detailed above, any change of information entered or resubmission of the return will result in a change to the authentication code. SRF 220.0 Exposure Concentrations is one of the four forms which requires audit, with a copy of the audit report being provided to APRA together with the annual return. If an amendment is made to the return after the audit report relating to the return has been submitted to APRA, then a copy of the amended return must be:
Lodged with APRA; and
Forwarded to the auditor of the return. The auditor will then consider the magnitude and significance of the amendment to the returns in order to assess whether the audit report will have to be re-issued.
General guidance for completion of SRF 220.0 Exposure Concentrations
Important!
Report all disclosures rounded to the nearest thousand dollars. Do not use decimal numbers i.e. when dividing the value to obtain a rounded balance to the nearest thousand dollars, ensure that the figure is whole.
Important!
There is no materiality limit applied to the disclosure of amounts within SRF 220.0 Exposure Concentrations. All balances must be recorded. Amounts cannot be omitted based on materiality levels. Each superannuation entity should use its own judgement in grouping items into meaningful categories (where applicable).
Important!
Zeros are not required where there is no dollar value for an item. If there is no balance for an item, leave it blank, as D2A recognises blanks as zeros.
Important!
If a superannuation entity has a number of like investments in the same counterparty, then these should be reported in aggregate.
For example, if a superannuation entity holds a number of bank bills with the same counterparty, reporting in aggregate is acceptable, as opposed to reporting them individually.
Important!
A liability for accrued member benefits does not form part of an exposure concentration. All accrued benefits are excluded from SRF 220.0 Exposure Concentrations.
Related party
A related party is defined in the current Australian Accounting Standards. For the purposes of Part A column 4 and Part B column 6:
parties are considered to be related if one party has the ability to either control the other party or to exercise significant influence over the other party in making financial and operating decisions; and
a related party transaction arises from a transfer of resources or obligations, including services of individuals or entities, between related parties, regardless of whether a price is charged.
The following specific guidelines should be taken into consideration:
Trustee of the reporting superannuation entity
This selection will be applicable where the exposure is between the reporting superannuation entity and the Trustee of the reporting superannuation entity.
For the purpose of this section, trustee of the reporting superannuation entity includes:
A corporate trustee;
A director of the corporate trustee;
An individual acting as a trustee rather than a corporate trustee; and
The spouse of a Trustee, or a spouse of a director of the corporate trustee of the reporting superannuation entity.
Trustee or director of a group entity of the approved trustee
This selection will be applicable where the exposure between the reporting superannuation entity and directors of an entity that is part of the consolidated group economic entity of the approved trustee. This includes exposures with the following directors who are not also a trustee or a director of the corporate trustee of the reporting superannuation entity (where they are such exposures are to be recorded under point A above):
Directors of the parent entity(s) of the approved trustee; and
Directors of subsidiaries of the parent entity of the approved trustee.
Group entities of the consolidated group economic entity
This selection will be applicable where the exposure between the reporting superannuation entity and an entity that is part of the consolidated group economic entity to which the approved trustee belongs. This will include the following group entities:
The parent entity(s) of the approved trustee;
Controlled entities of the parent entity(s) of the approved trustee; and
Joint ventures or associates of the parent entity(s) of the approved trustee.
A related entity of the trustee or a of director of the corporate trustee, of the superannuation entity and that entity is not a group entity
This selection will be applicable where the exposure between the reporting superannuation entity and an entity that is related to a trustee or a director of the corporate trustee of the reporting superannuation entity, but that entity is not part of the consolidated group economic entity to which the approved trustee belongs.
An entity that is related to a trustee, or a director of the corporate trustee of the reporting superannuation entity is to be interpreted as including:
The trustee, or director of the corporate trustee of the reporting superannuation entity, is a director of that entity/business; and
The spouse of a trustee, or the spouse of a director of the corporate trustee of the reporting superannuation entity, is a director of that entity/business.
Subsidiary, associate or joint venture of the reporting superannuation entity
This selection will be applicable where the exposure between the reporting superannuation entity and any subsidiaries, associates or joint ventures of the reporting superannuation entity.
This form is separated into 2 parts:
Part A – ‘look through’ not required
Exposures greater than 5% of the total assets of the superannuation entity to:
directly held investments;
investments that are held with external investment managers (such as investments in Pooled Superannuation Trusts or unit trusts); and
investments held via individually managed mandates/portfolios. This requires the reporting of the superannuation entity’s aggregate investment value held with an individual external manager (i.e. a ‘look through’ basis is not required in Part A).
Part B – ‘look through’ is required
Exposures greater than 5% of the total assets of the superannuation entity to:
directly held investments;
investments that are held with external investment managers (such as investments in Pooled Superannuation Trusts or unit trusts); and
investments held via individually managed mandates/portfolios. In this part a ‘look through’ to the underlying investments is required for individually managed mandates/portfolios. Exclude the aggregate investment to these managers as these are reported in Part A.
Important!
As for SRF 210.0 Statement of Financial Position, the ‘look through’ requirement does not extend to underlying investments in collective vehicles held with external investment managers e.g. Pooled Superannuation Trusts and listed unit trusts and unlisted public offer unit trusts, which should be reported in aggregate.
Examples of disclosure required – investments exposure
Example 1:
A superannuation entity holds ten different trusts (or investments) with one investment manager.
Exposure
Each of the ten trusts (or investments) are in excess of 5% of total assets of the entity.
Disclosure required
The aggregate of these trusts (or investments) should be reported in Part A with the name of the investment manager being disclosed under column (1).
The ten different trusts (or investments) should then be reported in Part B under column (1).
Where collective vehicles are used (i.e. investments have been reported in item 3.6 on SRF 210.0 Statement of Financial Position) and the investment manager uses the same ABN for each collective investment, aggregate the investments as a single exposure for reporting in Parts A & B.
Example 2:
A superannuation entity holds the following investments.
Exposure - Direct share holding in XYZ Corporation Limited which is >5% of total assets.
Disclosure required - This is reported in both Part A and Part B.
Exposure - Investment in ABC Pooled Super Trust which is >5% of total assets.
Disclosure required - This is reported in both Part A and Part B.
Exposure - Individual mandate managed by DEF Investment Manager which is >5% of total assets. This portfolio includes an investment in SampleCorp Ltd shares and in Prime Unit Trust, both of which are individually >5% of the superannuation entity’s total assets.
Disclosure required - In Part A report the investment with DEF Investment Manager as a single line item, but do not report the underlying investments in this portfolio (i.e. look through basis is not employed). In Part B report separately the investment in SampleCorp and the investment in Prime Unit Trust (i.e. look through basis is required), but do not report the aggregate investment in DEF Investment Manager.
Scope
1.1. A large exposure does not include the portfolio value or exposure to an asset class such as domestic equities, property, or an industry sector unless the value represents an investment in an individual asset (e.g. equity securities issued by one corporation) or a group of related counterparties (refer to 1.5 for guidance on determining related counterparties).
1.2. Exposures include claims and commitments of the superannuation entity recorded both on and off the balance sheet that are of the following nature:
(a) Credit exposures (i.e. such as a money market placement with a Bank or holding of a corporation’s debt securities);
(b) Asset exposures that are not in the nature of a credit exposure (e.g. a direct property investment);
(c) Exposures in the nature of a liability or obligation to a single party or group of related parties.
1.3. Off-balance sheet exposures refer to items that are not recognised in the statement of financial position of the superannuation entity, such as contingent assets and liabilities.
1.4. Where credit risk is unequivocally transferred to a third party by an irrevocable letter of credit or a direct guarantee, the exposure is to the third party.
1.5. In determining whether a group of counterparties are related, the reporting superannuation entity should treat:
Counterparties as related where they are linked by cross guarantees, common ownership, ability to control, financial interdependency, or other connections which, in the superannuation entity’s assessment, identify the counterparties as representing a single risk; and
All exposures underwritten by the same guarantor as a single risk.
1.6. Exposures of the reporting superannuation entity to related parties should be included.
Example of approach to aggregate exposure – single counterparty
The following is provided as a brief example of the approach APRA expects to be adopted in calculating the aggregate exposure to a single counterparty.
Example 3:
A superannuation entity holds the following investments in ABC Bank Limited:
Listed equity securities of ABC Bank Limited;
‘Over the Counter’ derivative financial instruments with ABC Bank Limited;
Funds placed or deposited with ABC Bank Limited;
Holding of debt securities issued by or guaranteed by ABC Bank Limited;
Direct property investment in which ABC Bank Limited is a lessee of over 50% of the commercial property.
APRA expects the following exposures to be aggregated in calculating the aggregate counterparty exposure to ABC Bank Limited:
The net market value of ‘Over the Counter’ derivative financial instruments with ABC Bank Limited where the derivative positions with ABC Bank Ltd are in a net gain position to the reporting superannuation entity (i.e. the reporting superannuation entity stands to receive funds or securities from ABC Bank Limited to settle the derivative position);
The value of funds placed or deposited with ABC Bank Limited; and
The net market value of the investment in debt securities issued by or guaranteed by ABC Bank Limited.
The value of listed equity securities of ABC Bank Limited held by the superannuation entity are not included in this aggregate calculation, as APRA considers it is unreasonable to extend the exposure concentration analysis to these type of holdings, even though the market value of such an investment would be adversely effected by a downgrading in the credit rating of ABC Bank Limited.
While the value of the superannuation entity’s holding of listed equity securities of ABC Bank Limited is not required to be aggregated as outlined above with other investments in ABC Bank Limited, the value of the holdings of listed equity securities of ABC Bank Limited will need to be individually reported in this form where the value of such a holding represents one of the 10 largest exposures of the superannuation entity.
Instruction guide for specific items
Part A
Disclose in PART A the 10 largest exposures (that are greater than 5% of the net market value of total assets) to external directly managed mandates/portfolios. Refer Example 1.
Important!
Exposure concentrations of investments should only be reported under SRF 220.0 Exposure Concentrations Part A column (3) ‘Net market value’ if they represent greater than 5% of total assets calculated using SRF 210.0 Statement of Financial Position item 5 ‘Total assets’ i.e. each individual line item disclosed at Part A must be greater than 5% of total assets.
Important!
The total sum of SRF 220.0 Exposure Concentrations Part A column (3) ‘Net market value’ must not exceed the total assets reported in SRF 210.0 Statement of Financial Position item 5 ‘Total assets’.
Name
Provide the name of the entity or counterparty for each exposure listed.
ABN
Where the investment/exposure is to an entity, provide the Australian Business Number (ABN) of that entity. When there is no ABN for the entity in question, leave this field blank.
Completion of the ABN fields is not mandatory to lodge returns. If the ABN is not recorded in the superannuation entities’ system, or is not known, leave the ABN blank. A Warning confirmation validation rule in D2A will request confirmation that the investment entity has not applied for an ABN. Tick the box as confirmation and enter the comment that ABN is not known.
Net market value
Report the net market value of the holdings as at the end of the reporting period for each exposure listed (report the net fair value if there is no net market value available).
Report exposures in descending order with the largest exposures listed first.
For this item, report asset exposures as a positive number and liability exposures as a negative number.
Related party
For the purposes of this form a related party of the superannuation entity includes an exposure(s) within the following categories (drop down box). Input “Yes” where the exposure is with a related party otherwise input “No”.
Rating grade
Refer to definitions provided in Part B column (7).
As per Part B, column (7), if a rating grade is unknown or not available use rating grade 6. Where investment managers cannot confirm their ratings a rating grade 6 should also be used.
Part B
Disclose in Part B the 10 largest exposures (that are greater than 5% of the net market value of total assets) of the superannuation entity. Refer Example 1.
Include the underlying investments the subject of external individually managed mandates or discretely managed portfolios. In Part B a ‘look through’ to the underlying investments is required for these portfolios.
Exclude the aggregate investment held with these managers.
Important!
Exposure concentrations of investments should only be reported under SRF 220.0 Exposure Concentrations Part B column (5) ‘Net market value’ if they represent greater than 5% of total assets calculated using SRF 210.0 Statement of Financial Position item 5 ‘Total assets’ i.e. each individual line item disclosed at Part B must be greater than 5% of total assets.
Important!
The total sum of SRF 220.0 Exposure Concentrations Part B column (5) ‘Net market value’ must not exceed the total assets reported in SRF 210.0 Statement of Financial Position item 5 ‘Total assets’.
Type
The type (description) of on-balance sheet exposures is determined from the following generic headings. When providing information in this column select from a drop down selection in the form providing the following classifications as applicable. Where none of the headings are applicable please provide a brief description:
(i) Securities purchased under agreement to resell
(ii) Receivables
Total investment income receivables;
Members contributions receivable;
Employer contributions receivable;
Contributions receivable from the Government;
Insurance proceeds receivable; and
Other receivables (provide a description).
(iii) Investments
Deposits;
Placement, loans and debt securities;
Equity securities of listed corporation and units in listed unit trust;
Equity securities of unlisted corporation, units in unlisted private trust and interest in venture;
Property holdings;
Pooled Super Trusts;
Wholesale trusts;
Investment and/or insurance policies held in statutory fund of life companies;
Investment in unlisted retail/public offer unit trust;
Leased assets; and
Other investments (provide a description).
(iv) Direct holdings of derivative financial instruments
(v) Borrowings
Securities sold under agreements to repurchase; and
Other.
(vi) Total Payables and Creditors
(vii) Members benefits payable
Example reporting for column 1 and 2 (below)
Type (description of exposure)(1)
Name of Entity/Counterparty (where applicable)(2)
Equity securities of listed corporations and units in listed trusts
XYZ Limited
Placement, loans and debt securities
ABC Pty Ltd
Property holdings
Acme Hotels
Name
Provide the name of the entity or counterparty for each exposure listed.
ABN
Where the investment/exposure is to an entity, provide the Australian Business Number (ABN) of that entity. When there is no ABN for the entity in question, leave this field blank.
As per Part A, completion of the ABN fields is not mandatory to lodge returns.
Externally managed
Where appropriate, mark “Y” for yes or “N” for no in this column for each exposure listed. For the purposes of this form, “Externally Managed Exposure” means an asset or investment:
in a Pooled Superannuation Trust (PST);
in a wholesale trust;
in a listed or unlisted unit trust including a retail/public offer unit trusts; and
that is subject to an external individually managed mandate or portfolio (i.e. an underlying asset of this portfolio that constitutes a large exposure to the superannuation entity).
Net market value
Report the net market value of the holdings as at the end of the reporting period for each exposure listed (report the net fair value if there is no net market value available).
Report exposures in descending order with the largest exposures listed first.
For this item, report asset exposures as a positive number and liability exposures as a negative number.
Related party
For the purposes of this form a related party of the superannuation entity includes an exposure(s) within the following categories. Input “Yes” where the exposure is with a related party, otherwise input “No”.
Rating grade
Report in this column where applicable, the APRA rating grade of a large counterparty exposure of the superannuation entity (i.e. report ratings 1 to 6 where applicable). The table below lists the APRA rating grade and the corresponding common rating grades from rating agencies.
Classification of rating grade of counterparty
The counterparty grades set out in the table below are to be used in classifying the rating grades for the purposes of this form. This table discloses the corresponding counterparty ratings of a number of rating agencies and the general classification APRA will apply to these ratings. The superannuation entity should request these rating grades directly from the counterparty (i.e. the other party with whom the transaction is being made) or investment manager, and should not rely on consumer rating agencies which rate collective investments.
APRA Classification
Standard & Poor’s
Moody’s
AM Best
Fitch
1
AAA
Aaa
A++
AAA
2
AA+AAAA-
Aa1Aa2Aa3
A+
AA+AAAA-
3
A+AA-
A1A2A3
AA-
A+AA-
4
BBB+BBBBBB-
Baa1Baa2Baa3
B++
BBB+BBBBBB-
5
BB+ or below
Ba1 or below
B+ or below
BB+ or below
6
Unrated
Unrated
Unrated
Unrated
Where the superannuation entity has investments with multiple rating from two or more of the rating agencies in the table above, the superannuation entity should consistently apply the rating of a single agency wherever possible. For example, a superannuation entity may have a number of counterparties that are rated by S&P and Fitch. In this case the entity should use a single agency that will be consistently applied whenever the individual ratings conflict.
The ratings in the above table from the respective rating agencies are generally consistent with long term rating/debt securities. Where superannuation entities invest in counterparties/securities that have only been issued with short term counterparty rating, then superannuation entities should attempt to match these ratings into the above grades.
Unknown rating grade
If a rating grade is unknown or not available use rating grade 6. Where investment managers cannot confirm their ratings a rating grade 6 should also be used.