Conclusion

The twin peaks model of regulation has now operated in Australia for many years. It should be maintained and strengthened. But there should be some adjustments made in respect of the regulation of superannuation and the BEAR.

As I said at the start of this chapter, both ASIC and APRA recognise that their approach to enforcement must change. That change cannot be effected by the passing of legislation. It must come from within the agencies. But it is also important to strengthen the accountability of both – internally, by each separately applying principles modelled on the BEAR, and externally, by both being accountable to a new oversight body.