including schools, hospitals, APRA decided to revise its aged care and social welfare original proposal, in a way programmes, amongst that would materially others. They argued that reduce the administrative alternative regimes and lost interest income ― seeking authorisation to costs for RCDFs without become an ADI, register as compromising APRA’s an RFC or operate a objective. registered MIS would be ― Under the revised proposal, administratively APRA would not require burdensome and the RCDFs wishing to offer associated costs would products to retail investors impede the religious and to operate under an charitable works of RCDFs. alternative regulatory Some submissions regime. APRA also suggested they be allowed modified its proposal such to continue to accept funds that RCDFs will continue to from retail investors but be able to raise funds from with additional conditions retail investors, but on a on the RCDF Exemption term or minimum call basis. Order, such as requiring an The proposed additional investor to provide a signed conditions would require declaration stating that they that any account offered to understand that their a retail investor lacking a investment is not equivalent stated maturity date have at to a deposit with an ADI least a 31-day notice period and does not enjoy the prior to any withdrawal. benefit of depositor Any term investment would protection. need to commence with a stated term of at least 31
including schools, hospitals, aged care and social welfare programmes, amongst others. They argued that alternative regimes ― seeking authorisation to become an ADI, register as an RFC or operate a registered MIS ― would be administratively burdensome and the associated costs would impede the religious and charitable works of RCDFs. Some submissions suggested they be allowed to continue to accept funds from retail investors but with additional conditions on the RCDF Exemption Order, such as requiring an investor to provide a signed declaration stating that they understand that their investment is not equivalent to a deposit with an ADI and does not enjoy the benefit of depositor protection. APRA decided to revise its original proposal, in a way that would materially reduce the administrative and lost interest income costs for RCDFs without compromising APRA’s objective. Under the revised proposal, APRA would not require RCDFs wishing to offer products to retail investors to operate under an alternative regulatory regime. APRA also modified its proposal such that RCDFs will continue to be able to raise funds from retail investors, but on a term or minimum call basis. The proposed additional conditions would require that any account offered to a retail investor lacking a stated maturity date have at least a 31-day notice period prior to any withdrawal. Any term investment would need to commence with a stated term of at least 31
Religious-Charitable-Development-Funds-RIS.docx