Penny Limperis

• APRA legal representative at:

- weekly Superannuation division strategy and matter prioritisation meetings;

- fortnightly Super@ APRA meeting with Super member and senior super executives;

- fortnightly APRA Policy and Advice division (super) meetings

- regular attendance at APRA Rehabilitation and Enforcement committee meetings

- monthly APRA and APRA Senior Leaders (Super)meetings;

- monthly APRA and Treasury Liaison meetings

• A member of APRA’s Senior Legal Leadership team, reporting to GC

- chair of weekly Senior Legal Leadership team meetings;

- leader of national Superannuation legal team (12 lawyers) which provides legal advice to APRA divisions in relation to trustee relief applications, trustee and trustee officer compliance with the prudential framework, law reform, Privacy Act and secrecy obligations and response to super-related external inquiries

• Led design of APRA Legal recent improvements to ‘ways of working’ and efficiency gains- work request system, knowledge management database, simplification and ‘front loading’ of legal advices; provision of ‘real time’ legal views; management of external legal resources

• Led APRA legal response to recent FRAA review of superannuation at APRA. (Involved in APRA response to Samuel APRA Capability Review & APRA submissions to Hayne Royal Commission into Financial Services)

• Led successful APRA administration of annual Performance Test (My Super and TDPs) by provision of legal advice on APRA obligations in SIS Act/Regulations & FSCODA

• Led creation of internal framework for APRA implementation of SIS Act trustee ownership provisions

• Led the legal strategy for APRAs approach to recent ‘trustee capital’ Court applications (following legislative reduction of trustee indemnities)

• Leading APRAs legal involvement in the review of trustee compliance with the SIS Act retirement strategy covenant, including the consideration of retirement income products and advice

• Collaborating with other APRA divisions to create APRA supervisory framework in relation to trustee ESG risks

• Liaising with ASIC, ATO, AUSTRAC, Treasury & OAIC and industry bodies to tackle emerging cyber and fraud risk response in the super industry

• Liasing with AFCA on systemic issues in super industry

•Headed up the Insurance legal practice group which providedlegal advice to APRA supervisors and policy teams in relation to the operations of general insurance and life insurance companies;

•Collaborated with other APRA divisions to integrate the prudential regulation of the private health industry;

•Led APRAs legal response to deteriorating financial position and governance of a friendly society;

•Collaborated with other APRA divisions to review ‘insurance in super’ practices & to recommend improvements to the prudential framework

• Worked with GC and Legal senior management team to implement APRA Legal’s restructure into specialist industry based units
• Lead the operations of the Superannuation legal practice group by creating a work request and prioritisation system; second counselling of legal advice; people management
• Collaborated with other APRA Divisions to create APRAs prudential standards and guidance in superannuation & implement the MySuper regime

• Introduced case management processes and legal precedents to build APRAs enforcement capacity
• Achieved APRAs first criminal conviction against a trustee officer for contravention of SIS Act offences, working with the AFP
• Involved in AAT disqualification proceedings brought by trustee directors appealing APRAs fitness and propriety decisions