It is also clear that the Government’s policy framework for assessing adequacy in old age goes beyond benefits that are specifically within the compass of a restricted definition of superannuation. That framework is constantly evolving as can be seen from the World Bank’s ruminations and the changes made to policy ever so frequently.

By APRA’s own admission, that the outcome may be a financial plan for the member’s overall situation doesn’t mean the fund’s intention, in providing funded access to advice, is to target benefits that might accrue outside superannuation. The fund’s intention is to ensure that the member’s core and ancillary benefits are calibrated within a best practice framework. The link between the financial plan and the fund’s purpose is reasonable, direct and transparent by any measure. To restrict the framework ab initio (from the beginning) runs real risks for the member. Surely that can’t be the regulator’s intention!

Paul Scully is a trustee director of State Super NSW and runs his own consultancy, Decision Horizons.