Register For Our Mailing List

Register to receive our free weekly newsletter including editorials.

Home / 3

Is APRA's Standard Risk Measure helpful?

Investors may have noticed that super fund Product Disclosure Statements (PDSs) now include a measure of risk called the ‘Standard Risk Measure’, or SRM. The intention is to provide greater risk disclosure for retail investors. I encourage people to be very careful when reading such disclosures and to think about risk in more ways than is simply described by this measure in the PDS.

The SRM was introduced by the Australian Prudential Regulation Authority (APRA) in 2011. It is a self-assessed estimation by the product provider of the number of times over a 20-year period that a fund is expected to deliver negative returns. For example, an Australian equity fund might appear in a High Risk band because it is expected to generate negative returns in 5 out of every 20 years. However, a fixed income fund might be in a lower Medium Risk band because negative returns occur only once every 2.5 years. APRA sought market feedback prior to implementing the SRM but the original version was adopted unaltered. The proposal was supported by two industry groups which is an interesting story in itself that I discuss later.

Any effort to improve risk disclosure in retail PDSs is welcome. However, there has been considerable debate around whether this SRM represents a step forward or whether it creates a set of issues which exceed the benefits of greater risk disclosure.

I have many doubts about the SRM but focus on two in this article: the measurement itself and the calculation method.

There are many measures of risk in finance and no single risk measure is perfect. A mosaic of risk measures blended with experience and a qualitative appreciation is probably our best chance to understand risk. Each measure on its own provides useful information but is flawed. Using volatility alone assumes that we live in a world which is perfectly normally distributed. Using VaR (Value-at-Risk, an estimation of an adverse, statistically-rare outcome) effectively provides a data point around the loss in a rare event but leaves us with little knowledge about what will happen in an everyday environment.

Size of loss is more important than the frequency

There are two key elements to understanding risk: the size of an event and the likelihood of that event occurring. Consider how this applies to the SRM, where the size of an adverse event is ignored. An event is simplified to be any negative return. So a negative 5% return is not viewed any differently to a negative 50% return. Those approaching retirement prior to the GFC can vouch that a 50% negative has a major impact on their livelihoods. Indeed any investor would surely take three negative 5% return years rather than a single year of negative 50%, yet the SRM may in fact guide them to take the opposite position and only expect to lose money in one year.

There are some strategies which have a very low likelihood of loss but if they do lose, they lose substantially. Consider a fund for instance which sells out-of-the-money options. It may consistently make money year after year and then suddenly lose everything when an option is exercised. Such funds would quite correctly report a very low SRM, but I question if this is the outcome desired by APRA.

Too much subjectivity

The other main area of concern is implementation of the calculation, which is undertaken by the product provider, although APRA may review the calculation methodology. Even though there exists much science around calculating risk statistics, there remains much subjectivity. It is possible that two highly respected risk managers could look at an identical product and calculate a different SRM. And both calculations could be defended as having been calculated by a professional and backed with appropriate research.

This then creates a dilemma for product providers. Offered two different SRMs, there would be internal pressure to adopt the lower measurement, thereby making their product appear less risky and hence more attractive. There have already been some industry reports of similar products having different SRMs and of bond funds having a measure close to some equity funds.

I can empathise with APRA on this decision to have providers do their own calculations. Banks are required to calculate on a daily basis the amount of market risk they are taking (measured by VaR) which determines a capital requirement for market risk. Because the number of banks operating in Australia is relatively small, APRA is very hands-on in reviewing the calculation methodologies used by each bank. However, in the funds management industry, there are a huge number of products and fund providers and APRA has likely decided it is impossible to regulate this calculation closely.

But there were other implementation choices. A small team could have calculated the risk numbers, with the product provider given an opportunity to object. This may have led to greater consistency. Overall, the self-implementation approach reduces the ability of the SRM to be relied upon as a way of comparing products.

Lack of agreement between industry bodies

A particularly interesting aspect of the SRM debate has been the role of various industry bodies.  Officially, the SRM is “the product of an ASFA (Association of Superannuation Funds of Australia) and FSC (Financial Services Council) working group, and is supported by ASIC (Australian Securities and Investments Commission) and Australian Prudential Regulation Authority (APRA).”  However, the SRM was proposed by APRA prior to the creation of the working group. Many other industry bodies have criticised the statistic, notably AIST (Australian Institute of Superannuation Trustees), Actuaries Institute, and ISN (the Industry Super Network). It is confounding that these industry bodies can have such strongly opposed views, and perhaps leaves a question mark over the consultation process.

All up, while it is an admirable objective to improve risk disclosure, even given the difficulties of such a large universe of products and providers, I can only describe this as awkward regulation. I hope the Standard Risk Measure is not relied upon too heavily by retail investors.

 

  •   21 February 2013
  • 2
  •      
  •   

RELATED ARTICLES

Are these assets the missing piece in Australian portfolios?

The pros and cons of taking the DIY super route

What can super funds learn from advisers?

banner

Most viewed in recent weeks

Why spending more in early retirement can improve lifetime income

Conventional wisdom encourages retirees to preserve superannuation. But if those likely to qualify for the Age Pension later in life spend a little more today, it may deliver higher lifetime income and a more stable retirement.

It’s time for LICs to die

A high-profile dividend cut and a prominent fund manager’s apology have reignited a long-running debate. If investors can access similar exposures more cheaply and efficiently elsewhere, what exactly is keeping LICs alive?

Testamentary trusts survived the trust tax. The drafting battle has just begun.

The fight over testamentary trusts looked settled. Then the draft legislation arrived. Hidden in a technical detail is a question that could force many families to rethink wills they thought were already future-proof.

Is it time to bail on Australian stocks?

For generations, Australian investors have backed banks, miners and dividends. But has that loyalty come at a cost? A look at the numbers raises an uncomfortable question about where future returns will come from.

The new capital gains tax trap for your portfolio

Investors have long accepted one portfolio rule without much question. A major tax shift could change that calculation entirely, forcing difficult trade-offs between risk, discipline and an overlooked cost lurking beneath.

How the typical Australian Family could save $844,350 in taxes

The value of a testamentary trust is not determined by wealth alone. Depending on circumstances, it can reduce the tax burden on inherited income, create efficiencies and help build intergenerational wealth.

Latest Updates

Fixed interest

Higher yields are creating opportunities in global bonds

Bond markets are adjusting to a new reality, but not in the ways investors expect. With markets repricing and capital competing for attention, investors may need to rethink where resilience and opportunity lie. 

Economy

Are we in a recession?

What if the warning signs are already everywhere? From supermarket aisles to company failures, investors are being bombarded with recession signals. But most face a different risk that can be just as dangerous for portfolios. 

SMSF strategies

Meg on SMSFs - Division 296 actuarial certificates

The tax bill might be yours, but the event that caused it may not be. A key Division 296 calculation can sometimes attribute earnings in ways that many SMSF trustees won't instinctively expect or fully appreciate.

Property

The first impact of negative gearing reform is not the tax bill

Negative gearing changes formally begin in 2027, but the first consequences may already be here. A subtle shift is quietly influencing who can borrow, how much they can access and which property strategies still stack up.

Economy

The oil market is running out of easy answers

The biggest threat to markets may not be what investors are watching. The numbers have stopped adding up and supply is harder to measure, with forecasts becoming simple guesses. A more fragile reality is being masked.

Investment strategies

The state of investor knowledge in Australia

Australians are investing more than ever, yet a surprising divide is emerging between those building wealth effectively and those making costly mistakes. Surprisingly, the gap has little to do with income, age or starting capital.

Taxation

Complexity and capital gains

A case study shows that the ‘30% minimum CGT’ is a poorly conceived tax that adds significant complexity to an already over-complex system. A less complicated model would create a much fairer progressive tax scale.

Sponsors

Alliances

  • ASA-Logo-RGB-ActiveGreen-web.png

© 2026 Morningstar, Inc. All rights reserved.

Disclaimer
The data, research and opinions provided here are for information purposes; are not an offer to buy or sell a security; and are not warranted to be correct, complete or accurate. Morningstar, its affiliates, and third-party content providers are not responsible for any investment decisions, damages or losses resulting from, or related to, the data and analyses or their use. To the extent any content is general advice, it has been prepared for clients of Morningstar Australasia Pty Ltd (ABN: 95 090 665 544, AFSL: 240892), without reference to your financial objectives, situation or needs. For more information refer to our Financial Services Guide. You should consider the advice in light of these matters and if applicable, the relevant Product Disclosure Statement before making any decision to invest. Past performance does not necessarily indicate a financial product’s future performance. To obtain advice tailored to your situation, contact a professional financial adviser. Articles are current as at date of publication.
This website contains information and opinions provided by third parties. Inclusion of this information does not necessarily represent Morningstar’s positions, strategies or opinions and should not be considered an endorsement by Morningstar.