04.
Remediation & Compliance
Fixing unit pricing errors to remediate customers and reduce regulatory risk
Engagement Snapshot
Services: Remediation, Compliance, Risk
Project Length: 8 weeks
Industry: Superannuation
>100 employees
The Situation
A mid-sized superannuation fund identified historical unit pricing discrepancies affecting multiple products. The issue posed financial, reputational, and regulatory risks - particularly given heightened oversight by APRA (Australian Prudential Regulation Authority).
The fund faced multiple challenges including:
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Immediate reporting to APRA
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Correcting historical pricing errors
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Compliance framework to avoid similar errors
With low tolerance for regulatory risk, leadership required urgent remediation and compliance reporting.
How We Helped
Our focus: Structured remediation with regulatory alignment from day one.
We were engaged to quickly and accurately identify the impacted members, quantify remediation amounts and prepare regulatory submissions.
Our work unfolded in four targeted phases:
1. Rapid Diagnostic Review
We conducted a deep dive into historical unit pricing data, identifying the root cause of pricing discrepancies and quantifying the client impact across products and time periods.
3. Remediation Framework
We developed a compensation and correction model that ensured impacted members were treated fairly while minimising financial leakage for the fund. We cross-checked results across data sources to improve accuracy.
2. Framed Initiatives for Comparison
We prepared APRA-ready reports, outlining both the issue and the corrective actions. We supported the client in drafting clear, transparent communications for regulators and trustees.
4. Process and Control Uplift
To prevent recurrence, we redesigned unit pricing controls, governance checks and escalation procedures - embedding compliance into day-to-day operations.
The Impact
1 / Full APRA compliance achieved
The remediation framework and reporting were accepted by APRA with minimal additional follow-up requests or no penalties.
2 / Member confidence protected
Impacted members were compensated accurately and communicated with proactively, resulting in zero complaints escalated to the regulator.
3 / Stronger compliance controls and checks
Updated compliance framework with automated checks, additional controls, governance checks and escalation procedures to reduce likelihood of similar future errors.