APRA confirms ASIC demarcation over Shield, First Guardian

The Australian Prudential Regulation Authority (APRA) has revealed to Senate Estimates that the Australian Securities and Investments Commission (ASIC) held concerns an APRA review of Macquarie Investment Management risked impeding an ASIC investigation.
APRA was questioned during Senate Estimates about whether APA held any concerns about the Shield and First Guardian funds before being informed by ASIC and confirmed that it was not aware because it is ASIC’s job to regulate Managed Investments Schemes (MISs).
APRA said it had been informed by ASIC in December, 2023, about ASIC’s work relating to Macquarie Investment Management with respect to Shield and said discussions had taken place between the two regulators regarding APRA’s intention to require MIML to have a review by an independent third party.
“The review was in relation to MIML’s investment governance. ASIC had concerns that such action by APRA could impede their investigation. Following these discussions, APRA proceeded with its requirements on MIML,” APRA’s answer said.
“After being informed by ASIC in August 2024 of the work in relation to First Guardian, ASIC again expressed concerns that any APRA action could impede their investigation. It was agreed that ASIC would lead with their work to avoid any such risk,” it said adding that, “Such interactions are inherent in the twin peaks model and consistent with the terms of the APRA and ASIC Memorandum of Understanding”.
APRA acknowledged in its answer that while it was carrying out work around platform governance, this was not related to Shield and First Guardian.
“APRA’s platforms thematic was scoped in late 2024, with the bulk of the work completed in 2025. The work was conducted to see whether trustees were meeting their obligations under the prudential framework,” APRA’s response said.
“It was not as a result of the First Guardian/Shield issues. However, the failures of these MISs heightened our concerns regarding investment governance hence we accelerated delivery of our initial findings which were publicly released in October 2025 and enforcement action taken in December 2025,” it said.
“This work is ongoing, and APRA continues to closely supervise platform trustees consistent with our mandate. We are also engaged with the Government on its possible reforms to address issues arising out of First Guardian and Shield. As part of this work, we will also give consideration to whether any enhancements to our prudential standards and guidance might be beneficial.”









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