One wonders whether any legal rebuttal can be made against APRA...

One wonders whether any legal rebuttal can be made against APRA based on the absurdity of some of their conditions and findings. The Show Cause notice is strewn with shifted goal posts and requirements demonstrative of APRA's incompetence or Kafka-esque malice (perhaps both).

For example, the "Managed Action Plan" (MAP) produced by APRA on the 4th of September required appointing a suitably skilled independent executive to lead the dedicated business function. 

APRA then complain that IOOF have not appointed an appropriately skilled and experienced person to head the dedicated business function to support the AREs. The appointment of the interim CEO to this role does not satisfy the requirement or intent of the MAP item (which was required to be completed by 1 October 2018).

You'd have to think even APRA would be aware that headhunting and employing such an individual in less than a 4 week period is not only improbable, but downright impossible.