Superannuation Fees and Performance ING DIRECT

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Superannuation Fees and Performance Sydney Melbourne Level 1 Level 20 2 Martin Place 303 Collins Street Sydney NSW 2000 Melbourne VIC 3000 T +61 2 9293 3700 T +61 3 8621 4100 ABN 35 003 186 883 F +61 2 9233 5847 F +61 3 8621 4111 AFSL 239 191 ricewarner.com

Table of Contents 1. Executive Summary...2 1.1 About this report...2 1.2 Key findings...2 2. Total superannuation fees...5 2.1 Total fees and the overall trend...5 2.2 Variations by sector...6 2.3 MySuper fee...7 3. Investment management fee...9 3.1 Fees by asset class...9 3.2 Active and passive fees...9 3.3 Fees vs. performance... 11 4. Impact of fees on projected balances... 12 4.1 Impact of fees on retirement savings... 12 4.2 Benefit of reviewing superannuation funds & consolidation... 16 This report constitutes a Statement of Advice as defined under the Financial Services Reform Act. It is provided by Rice Warner Pty Ltd. which holds Australian Financial Services Licence number 239 191. This report should not be distributed, in whole or in part, without Rice Warner s prior written consent. January 2015/260452_5 Page 1 of 16

1. Executive Summary 1.1 About this report ING Direct has engaged Rice Warner (Rice Warner) to analyse trends in superannuation fees, paying particular attention to investment management fees and their impact on balances across age cohorts at retirement. The analysis in this report is based on data sourced from Rice Warner s proprietary databases and published APRA statistics, and supplemented by superannuation fund Product Disclosure Statements, annual reports and superannuation fund surveys conducted by Rice Warner. We have also collected fees from legacy retail products directly from financial institutions. However, Self-Managed Super Funds (SMSFs) are excluded. We define superannuation fees to be amounts charged to members for the costs of managing the fund. Several items are excluded, including: Taxes and insurance premiums. Fee subsidies made by employers and not charged to the fund. Fees for personal financial advice which are paid direct by members and not taken out of fund fees. Tax credits for deductions on fees and insurance premiums which some funds retain in a separate reserve rather than crediting back to members. 1.2 Key findings 1.2.1 Total fees and MySuper We estimate that overall fees for the whole superannuation industry, expressed as a percentage of assets, averaged 1.15% (or 115 basis points [bps]) for the year to 30 June 2014 (on assets of $945 billion as stated in the 2013 APRA statistics). This represents a slight reduction on 2013 fees (1.20%), with retail funds attracting the highest average fee (1.57%), compared to public sector funds which are the sector with the lowest average fee of only 0.60%. While many large industry funds continue to invest actively and have not materially altered their strategic asset allocations, the percentage of assets passively managed by retail funds is close to 50%. 1.2.2 Impact of fees on projected balances Our analysis and stochastic modelling show the impact that fees can have on projected retirement balances, across different age groups and account balances. High fees have a larger impact on younger members. Table 1 illustrates the impact that fees can have on retirement balances for different members (from those aged 30 through to 60), other things being equal. January 2015/260452_5 Page 2 of 16

Table 1. Projected retirement balances Age 30 40 50 60 Retirement balance with nil fee Male 511,000 440,000 359,000 275,000 Female 473,000 356,000 254,000 208,000 Retirement balance using lowest fee: 0.51% Male 459,000 404,000 339,000 269,000 Female 425,000 328,000 241,000 203,000 Retirement balance with lower quartile fee: 0.93% Male 421,000 377,000 232,000 264,000 Female 390,000 307,000 230,000 199,000 Retirement balance with weighted average fee: 1.15% Male 402,000 364,000 315,000 261,000 Female 373,000 297,000 225,000 197,000 Retirement balance with upper quartile fee: 1.57% Male 370,000 340,000 301,000 256,000 Female 343,000 278,000 216,000 194,000 Retirement balance using highest fee: 2.33% Male 319,000 301,000 276,000 248,000 Female 296,000 248,000 200,000 187,000 Retirement balance with Industry MySuper fee: $70 pa + 0.80% fee Male 429,000 383,000 326,000 265,000 Female 397,000 311,000 232,000 200,000 A summary of assumptions used in these projections is given in Section 4.1. As employers often subsidise fees for Corporate and Public Sector funds, these funds have consequently been excluded from the analysis. January 2015/260452_5 Page 3 of 16

This report was prepared and peer reviewed for ING Direct by the following consultants. Prepared by Peer Reviewed by Salvador Saiz Senior Consultant Michael Berg Senior Consultant Telephone: (02) 9293 3738 Telephone: (02) 9293 3724 Salvador.saiz@ricewarner.com michael.berg@ricewarner.com Nathan Bonarius Consultant Head of Market Insights Telephone: (02) 9293 3738 Nathan.bonarius@ricewarner.com January 6, 2015 January 2015/260452_5 Page 4 of 16

2. Total superannuation fees 2.1 Total fees and the overall trend We estimate that overall fees for the whole superannuation industry, expressed as a percentage of assets, averaged 1.15% (or 115 basis points [bps]) for the year to 30 June 2014. This represents a total fee of approximately $14.9 billion based on assets of $1.3 trillion as stated in the 2014 June Fund Level Performance APRA statistics (excluding SMSFs). This is a slight reduction on 2013 fees (1.20%), with the retail funds attracting the highest average fee (1.57%), compared to public sector funds with an average fee of only 0.60%. Fees have been impacted by a number of factors over this period. Some factors serve to decrease fees which include: A number of mergers between industry funds and some between retail corporate master trusts resulting in greater economies of scale. Continuation of the outsourcing of superannuation for larger companies and the winding up of smaller corporate funds. There is keen competition amongst the specialist multi-employer funds to win this business. The new arrangements are usually struck at an MER some 10 to 30 bps per annum lower than the standalone corporate fund. A reduction in the number of accounts in the system, due to an element of increase in consolidation of accounts as well as transfer of small lost accounts to the ATO. Greater awareness of advice fees. Increased average account balances with high market returns. Lower investment costs due to increased investment in passively or indexed portfolios, which cost less than actively managed equivalent portfolios. In particular, a number of low cost personal superannuation products have now accumulated significant funds under management which is now having a material impact on average fees in that segment. For these products, the cost of advice has been removed (as separate fees for advice are charged where applicable) and investment management fees are lower, reflecting higher allocations to indexed investment. Other key drivers influencing fee increases over the last four years are: Higher advertising and marketing expenses as a result of competition between funds as more become public offer. Higher investment fees due to performance related charges by fund managers. Performance based fees have become more common and many active managers have been able to outperform the index. A shift in investments to higher cost asset classes, including direct investments in infrastructure, private equity, hedge funds and other international assets. Significant growth in member engagement and financial advice services, marketing and advertising, particularly by not-for-profit funds. Substantial investment in modern administration platforms. Increased compliance costs with the introduction of new legislation as part of the Stronger Super reforms. January 2015/260452_5 Page 5 of 16

2.2 Variations by sector Although fees as a whole have broadly decreased over time, the experience across sectors does vary. Table 2 expresses the average fees charged by each sector, in basis points (bps). Table 2. Segment Average fees by sector Fee rate (bps) % 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 # change over 10 years Corporate 77 78 76 73 77 80 79 79 78 69-9.8% Retail 198 189 185 181 183 185 170 164 157 157-20.7% Industry 116 113 110 107 117 126 113 110 107 93-19.6% Public Sector 68 70 70 69 75 81 82 79 76 60-11.8% Total excluding small funds 142 139 127 132 136 140 129 124 120 115-19.2% # Weighted average fee based on our 2014 fee research. The numbers are estimates only. Fee rates for retail are assumed to be the same as the 2013 figure due to lack of data. Over the ten year period to 2014, average fees have reduced by 42 bps for Retail providers and 23 bps for Industry funds. For both of these sectors, the above reductions represent about 20% of the fees that applied in FY2005. Note that total fees by sector for 2014 are high level estimates only. These are based on the weighted average per member administration fee and asset-based fee for each sector in our database and the total number of members and total assets as reported in the 2013 APRA statistics. 2.2.1 Corporate A corporate fund is an employer-sponsored superannuation fund managed under its own trust deed. It is sponsored by a single employer or several closely related employers. The administrative and legal requirements of the current superannuation regime include APRA RSE licences. These factors have added significant complexity and compliance risk for corporations, and many have wound up their funds and transferred members and assets into other funds. This has reduced the number of corporate funds and, as it is the smaller funds which have exited first, the average size of the remaining funds has increased. This has led to a modest decrease in total fee for this section of 9.8% over the past 10 years. Many corporate funds have a reasonable size defined benefit (DB) component, which is often closed to new members. The total fee associated with this component, such as the cost on triennial actuarial reviews, is typically stable in dollar terms even though the assets have been reducing as members leave the DB arrangement or as lifetime pensions are paid out. This reflects the costs of dealing a combination of increasingly stringent regulation and periods of market volatility. As a result, the total fee for the corporate segment did not change as much as other sectors. 2.2.2 Retail Retail funds include Master Trusts and other retail funds. January 2015/260452_5 Page 6 of 16

Over the years, retail funds have been criticised as being more expensive than industry funds and in combination with the FoFA reforms have made a substantial effort to reduce fees to members. Our research shows that total fees have been reduced by approximately 21% from 2005 to 2014, which has led to a convergence between retail and industry funds fees. 2.2.3 Industry Similarly to corporate funds, the number of industry funds is gradually declining as larger funds search for growth in an environment of negative member growth and as smaller funds face growing administration burdens as a result of the Stronger Super reforms. APRA statistics show that there were 50 industry funds at 30 June 2014 with total assets of $324.0 billion. This compares with 67 funds as at 30 June 2011 with assets of $249.7 billion. As assets under managed increase mainly due to mergers and acquisitions, industry funds are able to take advantage of economics of sale and purchasing power granted by large size. This has helped them to reduce total costs to members by approximately 20% since 2005. 2.2.4 Public Sector Public sector funds are funds operated for the benefit of the employees of Government departments and agencies. There is a strong trend away from defined benefit plans, many unfunded, to defined contribution plans, particularly for new employees. Most funds are open to public sector employees only. As a result, management of some aspects of these funds is relatively simple (e.g. they do not have to contend with multiple pay centres) and the corresponding fees are therefore lower. However, this is starting to change with some large funds moving to public offer status. Further, some funds have complicated benefit designs that can lead to higher costs. Over the ten years to 2014, fees for Public Sector funds declined by 11.8%. 2.3 MySuper fees Employers have been required to make contributions to compliant MySuper products since 1 January 2014. MySuper product average fees as at 30 June 2014 are given in Table 3. January 2015/260452_5 Page 7 of 16

Table 3. MySuper product fees - 2014 Average annual fee by account balance (% of assets) Segment Average annual $ per member fee Average % of assets fee $5,000 $20,000 $50,000 2011 Corporate 47 0.62% 77 170 355 Retail 64 1.61% 144 385 867 Industry 68 0.76% 106 220 449 Public Sector 28 0.58% 57 144 317 Total 63 0.92% 109 248 525 2014 Corporate 89 0.77% 127 242 473 Retail 72 0.96% 120 263 551 Industry 73 0.78% 112 229 464 Public Sector 34 0.84% 76 202 454 Total 70 0.80% 108 222 450 Although overall fees have reduced since 2011, some sectors have experienced a slight increase in fees. January 2015/260452_5 Page 8 of 16

3. Investment management fees 3.1 Fees by asset class Investment management fees vary significantly by asset class. We have performed an analysis of fees based on a simple average of available sector options in our database. The results of this analysis are given in the tables below. Table 4. Fees for single asset class options includes active and indexed options Single asset class options Base fee Performance base fee Minimum Average Maximum Minimum Average Maximum Australian equities 0.20% 0.94% 3.65% 0.00% 0.04% 0.43% International equities 0.20% 1.04% 3.19% 0.00% 0.04% 0.59% Property 0.15% 0.77% 2.88% 0.00% 0.01% 0.25% Fixed interest 0.10% 0.58% 2.75% 0.00% 0.00% 0.08% Cash 0.00% 0.17% 0.80% 0.00% 0.00% 0.10% Alternatives 0.40% 1.42% 2.70% 0.00% 0.00% 0.00% Table 5. Fees for single asset class options active options only Single asset class options Base fee Performance base fee Minimum Average Maximum Minimum Average Maximum Australian equities 0.25% 0.96% 3.65% 0.00% 0.04% 0.43% International equities 0.26% 1.05% 3.19% 0.00% 0.04% 0.59% Property 0.15% 0.86% 2.88% 0.00% 0.02% 0.25% Fixed interest 0.10% 0.60% 2.75% 0.00% 0.00% 0.08% Alternatives 0.40% 1.41% 2.70% 0.00% 0.00% 0.00% Table 6. Fees for single asset class options indexed options only Single asset class options Base fee Performance base fee Minimum Average Maximum Minimum Average Maximum Australian equities 0.20% 0.57% 1.33% 0.00% 0.00% 0.00% International equities 0.20% 0.79% 1.84% 0.00% 0.00% 0.00% Property 0.24% 0.43% 0.84% 0.00% 0.00% 0.00% Fixed interest 0.20% 0.47% 1.74% 0.00% 0.00% 0.00% January 2015/260452_5 Page 9 of 16

3.2 Active and passive fees Pressure to reduce headline fees for MySuper products has led a number of funds to do this by employing passive strategies or reducing or removing exposure to more expensive alternative strategies. With the introduction of MySuper our research indicates that: Many large industry funds continue to invest actively and have not altered their strategic asset allocations. Some smaller industry funds have increased the proportion of passively managed assets in their portfolios to reduce costs. There is an emerging trend towards medium and large industry funds bringing more of the management of their assets in-house. A representative basket of leading retail funds found the average percentage of assets passively managed has almost doubled, from 24.0% in 2011 to 46.6% in 2013. Corporate and public sector funds have largely left their allocations unchanged. A demonstration of the impact of passive investments for a representative basket of funds for which passive asset allocation percentages were available is given in Table 7. This shows that those funds with a greater use of passive strategies attract lower investment costs. Table 7. Impact of passive asset allocations on fees (sample of leading funds) Passive Allocation % Retail >75% 0.39% 50% - 75% 0.50% 25% - 50% 0.59% <25% 0.84% Retail fund MySuper products exhibit a larger degree of variation in the use of active or passive investment strategies, when compared to industry funds. Industry funds MySuper products generally have a low degree of passive allocation. Retail funds, however, have designed new products in response to the perceived competitive tension in the default market by designing a range of MySuper products with significantly different levels of passive or active management. As outlined in Table 3, this has resulted in different fees for different MySuper products that reflect the degree of active or passive management. If only the passively managed options are considered, the investment fees for single asset class options are reduced significantly. Table 8. Fees for single asset class options indexed options only Single asset class options Base fee Australian equities 0.57% International equities 0.79% Property 0.43% Fixed interest 0.47% January 2015/260452_5 Page 10 of 16

3-year return The most significant decreases in base fees between active and passive management are for property, Australian and international equities (over 25 basis points). 3.3 Fees vs. performance The following analysis aims to identify if there is a relationship between investment management fees and the performance of multi-sector options. For this analysis, we have focused on the 3-year annualised return to 30 June 2013. The results are shown in Graph 1. Graph 1. Multi-sector investment options Growth exposure between 50% and 80% 20.00% 15.00% 10.00% 5.00% 0.00% 0.00% 0.50% 1.00% 1.50% 2.00% 2.50% 3.00% -5.00% IMF Active Passive Linear (Active) Investment returns are net of tax and fees. In general, investment options employing a greater use of active management strategies, as well as alternative assets, are more costly. In return for higher compensation, it is expected that these strategies/investment managers will be able to add value, diversify across a wider range of assets, and outperform benchmarks or other objectives. However, Graph 1 provides no clear indication of higher fees paid for active strategies leading to better overall net performance over three years, for our sample of options. (This naturally does not rule out specific strategies and/ or specific funds adding value on a net of fees basis.) January 2015/260452_5 Page 11 of 16

4. Impact of fees on projected balances 4.1 Impact of fees on retirement savings We have modelled the impact of various levels of fees on different cohorts of members by age and gender. As employers often subsidise fees for Corporate and Public Sector funds, these funds have consequently been excluded from the analysis. As a result, the scenarios we have used are given in Table 9, using average balances for Industry and Retail Sector members, as measured in our 2013 projections report. Using the below return assumptions and applying the strategic asset allocation of the Living Super Balanced Fund for comparability, we compared the impact of fees across the different scenarios. Members are assumed to receive only superannuation guarantee contributions into superannuation and do not receive additional voluntary contributions. Table 9. Projection assumption account balance and salary Scenario Gender Age Account balance Annual salary 1 Male 30 24,000 75,000 2 Male 40 68,000 85,000 3 Male 50 121,000 100,000 4 Male 60 191,000 120,000 5 Female 30 21,000 70,000 6 Female 40 45,000 75,000 7 Female 50 65,000 90,000 8 Female 60 137,000 110,000 Table 10. Projection assumption investment option and return Living Super Balanced Asset class Real return (p.a.) net of tax and CPI* Asset allocation Cash 1.2% 50% Aus Shares 5.8% 30% Intl Shrs (unhedged) 5.4% 10% Intl Shrs (hedged) 5.8% 10% Portfolio return (p.a.) 3.46% 100% * CPI of 2.8% has been applied Based on Living Super s Balanced Fund, which has no administration or management fees, and assuming a member s assets are all invested in this option (which has 50% of its assets in an ING cash account and the other 50% in shares), their retirement balance for a retail male member under scenario 1 would be $511,000 in today s dollars. This projected balance would reduce with the introduction of fees. January 2015/260452_5 Page 12 of 16

Table 11. Note: current fees for the ING Select range of managed investments are an investment fee of 0.25% p.a. and an administration fee of 0.50% p.a. with a cap on the administration fee of $1,000 p.a. Projection results Male, age 30 Scenario Account balance at retirement Assumptions Age 30 Account balance $24,000 Annual salary $75,000 Projection results Nil fee $511,000 Minimum fee of 0.51% $459,000 Lower quartile fee of 0.93% $421,000 Weighted average fee of 1.15% $402,000 Upper quartile fee of 1.57% $370,000 Maximum fee of 2.33% $319,000 Average MySuper fee of $70 pa + 0.80% $429,000 January 2015/260452_5 Page 13 of 16

Retirement balance Retirement balance A summary of results for all scenarios is detailed in the graphs and table below. Graph 2. Retirement balance Male 600,000 500,000 400,000 300,000 200,000 100,000 0 30 40 Age 50 60 Nil fee Minimum fee: 0.51% Lower quartile fee: 0.93% Weighted average fee: 1.15% Upper quartile fee: 1.57% Maximum fee: 2.33% Industry MySuper fee:$70 pa + 0.80% Graph 3. Retirement balance Female 600,000 500,000 400,000 300,000 200,000 100,000 0 30 40 Age 50 60 Nil fee Minimum fee: 0.51% Lower quartile fee: 0.93% Weighted average fee: 1.15% Upper quartile fee: 1.57% Maximum fee: 2.33% Industry MySuper fee:$70 pa + 0.80% January 2015/260452_5 Page 14 of 16

Table 12. Projected retirement balances Retirement balance with nil fee Age 30 40 50 60 Male 511,000 440,000 359,000 275,000 Female 473,000 356,000 254,000 208,000 Retirement balance using lowest fee: 0.51% Male 459,000 404,000 339,000 269,000 Female 425,000 328,000 241,000 203,000 Retirement balance with lower quartile fee: 0.93% Male 421,000 377,000 232,000 264,000 Female 390,000 307,000 230,000 199,000 Retirement balance with weighted average fee: 1.15% Male 402,000 364,000 315,000 261,000 Female 373,000 297,000 225,000 197,000 Retirement balance with upper quartile fee: 1.57% Male 370,000 340,000 301,000 256,000 Female 343,000 278,000 216,000 194,000 Retirement balance highest fee: 2.33% Male 319,000 301,000 276,000 248,000 Female 296,000 248,000 200,000 187,000 Retirement balance with Industry MySuper fee: $70 pa + 0.80% fee Male 429,000 383,000 326,000 265,000 Female 397,000 311,000 232,000 200,000 Note that the above projections include MySuper and that the cost of any insurance has been ignored from this analysis. January 2015/260452_5 Page 15 of 16

4.2 Benefit of reviewing superannuation funds & consolidation The average Australian superannuant has 2.1 accounts. Some of these accounts serve deliberate purposes such as diversifying investments or retaining insurance cover. However, a large number of them have arisen from members not consolidating their accounts when changing employers. By consolidating multiple superannuation accounts into one fund, members can avoid paying multiple sets of administration fees, investment management fees and insurance premiums for different accounts they have. This report s analysis provides further evidence of the need for superannuation members to review their superannuation arrangements, either themselves or by seeking the help of a financial adviser, with a view to: Identifying the investment strategy/option most suitable to the member s individual circumstances. Reducing costs by switching to a fund with lower fees (without sacrificing investment performance and/or consolidating funds). Obtaining cheaper insurance cover by moving to another fund or switching between fixed and unitised cover. January 2015/260452_5 Page 16 of 16