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PFA Submissions

Through robust regulatory advocacy, we ensure our members' perspectives are effectively represented, influencing the development of commercially viable policies and fostering a regulatory environment that supports innovation, competitiveness, and long-term success. By championing the interests of our members, we aim to strengthen the industry's foundations and enable its continued evolution.

At the PFA, we enhance our role as a trusted thought leader and proactive advocate for the unlisted property funds sector. Actively engage with policymakers, industry associations, and regulatory bodies to shape and promote well-informed policies that drive sustainable growth and unlock investment opportunities within the sector.

The PFA Issues and Regulatory Committee (IRC) is available to answer any PFA member questions.

The IRC meets with ASIC regularly – please contact the IRC if you have a question or an issue you would like to see raised with the regulator. Please email any IRC correspondence to pfa@propertyfunds.org.au

 

You can read submissions from the PFA IRC Committee below.

 

 

May 14, 2025
PFA Submission in response to Consultation Paper 383
The PFA welcomed the opportunity to comment on ASIC’s Consultation Paper 383: Reportable situations and internal dispute resolution data publication (‘CP 383’). We appreciate ASIC’s commitment to improving transparency, accountability, and consumer outcomes in the financial services sector.

However, we have concerns regarding ASIC’s plan to publish two dashboards of firm-level Reportable Situations (‘RS’) and Internal Dispute Resolution (‘IDR’) data, which will put breach and complaints data into the public domain, on the basis that the proposed approach may undermine the very policy objective ASIC seeks to achieve.
Apr 28, 2025
PFA Submission to ASIC Discussion Paper – Australia’s evolving capital markets: A discussion paper on the dynamics between public and private markets
The PFA put forward this submission that relates to the ASIC’s discussion paper titled ‘Australia’s evolving capital markets: A discussion paper on the dynamics between public and private markets’ released in February 2025 (‘Discussion Paper’).
Sep 29, 2023
PFA Submission to Treasury's Review of Managed Investment Schemes
The Property Funds Association of Australia (PFA) recently made a submission to Treasury’s review of Managed Investment Schemes (MIS) in response to the consultation paper released by Treasury in August 2023. Our submission was tabled on 29 September 2023 and addressed several key issues facing unlisted property funds, including potential changes to wholesale investor thresholds, and the definition of liquid assets.

We engaged with PFA members including fund managers, and drew on the substantial compliance and legal experience of the PFA Issues and Regulatory Committee (IRC) in drafting the submission.
Jul 21, 2023
Advocacy Alert: Further changes to proposed Thin Capitalisation Rules
Prior to the Federal Budget, on 16 March 2023, the Government released draft legislation proposing significant changes to Australia’s thin capitalisation rules.

However, the thin capitalisation rules were not mentioned in the budget. At the time of writing, there has been no announcement on the outcome from the consultation process and no updates made to the draft legislation.

If enacted in their current form, the proposed changes will apply to income years commencing on or after 1 July 2023, with no grandfathering or transitional rules for existing arrangements.