Ann: IOOF response to APRA notice and action, page-142

Good advice, although I have a different opinion on the transcript - there are no material issues beyond what's already been widely reported. The change in Reserves Policy between 2013 and 2017 is possibly an exception; this strengthens APRA's case even though they were unaware of it until the RC.

What does come across very clearly is that the people at APRA really don't like the people at IOOF, and that APRA seem to work in the realm of the vague rather than the concrete. There's a lot of subjective talk about "culture" and "having concerns" - all nice millennial stuff but nothing on which to hang a court case.

In IOOF's investor presentations, Chris Kelaher and others come across as no nonsense, facts-based people. You can well imagine them being blunt and ultimately obstructive when faced with a dithering Regulator that can't articulate objectively what it wants.

IOOF's board and management have certainly failed in the sense that one of their jobs is to glad-hand APRA. It's less clear that they have done something (or omitted to do something) that deserves this punishment.