Establishing Real-Time Oversight Across 30 Delegated Investment Managers

Following the removal of ASIC safe harbour provisions, a leading superannuation fund was required to demonstrate effective oversight of transaction reporting performed by over 30 delegated investment managers (IMs).

This created a significant operational and regulatory challenge:
how to gain consistent, transparent and defensible oversight across multiple external parties, each with their own systems, data models and reporting processes.

By implementing En:ACT, the client established a centralised, real-time oversight framework, enabling:

• Direct ingestion of source and submission data from all delegated IMs  

• Full visibility across 100% of transactions and reportable fields  

• A unified dashboard to monitor performance across all managers  

• Clear identification of errors, root causes and responsible parties  

The result was a shift from limited, retrospective oversight to continuous, data-driven control, providing the super fund with the ability to actively govern, challenge and evidence the performance of its delegated reporting model.

The removal of ASIC safe harbour fundamentally changed the regulatory expectation: The super fund remained accountable for reporting accuracy, even where reporting was delegated to external investment managers.

This introduced a set of complex challenges:

• Fragmented data landscape across 30+ IMs, each with different systems and formats  

• No consistent oversight framework, with limited ability to compare performance  

• Reliance on IM self-reporting, often delayed and non-standardised  

• Lack of transaction-level transparency, preventing effective challenge  

• Inability to evidence control to regulators, particularly across the full reporting population  

In practice, the client could not confidently answer:

• Which managers are performing well or poorly?  

• What errors are being made, and why?  

• Whether issues are being fully and permanently remediated  

Conventional solutions were not designed for delegated oversight at scale:

• They rely on submission-level or aggregated reporting, not transaction-level insight  

• They require standardised data inputs, which delegated IMs cannot provide consistently  

• They deliver periodic reporting, rather than continuous oversight  

• They do not provide cross-manager comparability or benchmarking  

Critically, they fail to give the asset owner independent, verifiable control over delegated reporting.

En:ACT enabled the super fund to establish a centralised oversight layer across all delegated managers, without requiring changes to each IM’s operating model.

1. Direct Data Ingestion from All Delegated Managers

En:ACT ingests data directly from each IM, regardless of:

• Source systems (OMS, EMS, custodians, brokers)  

• File formats or data structures  

• Reporting processes or jurisdictions  

This creates a standardised, normalised data layer, providing:

• Complete coverage across all delegated reporting activity  

• A single, consistent view across all managers  

• Immediate scalability without complex integration  

This capability is critical, as En:ACT is designed to ingest raw data from any source system without reliance on pre-transformed schemas.

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2. Full Population Validation Across Every Manager

Each IM’s reporting is independently assessed:

• 100% of transactions  

• 100% of reportable fields  

• Against regulator-aligned rules  

This ensures:

• No reliance on sampling  

• Consistent validation methodology across all managers  

• Immediate identification of reporting issues  

Providing true comparability and control across the delegated model.

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3. Centralised Delegated Oversight Dashboard

The super fund is provided with a single, consolidated dashboard enabling:

• Performance comparison across all 30 IMs  

• Drill-down from entity → transaction → field level  

• Visibility of error rates, trends and issue types  

• Identification of systemic vs isolated issues  

This transforms oversight from:

high-level reporting → granular, actionable insight

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4. Full Transparency into Every Error

For every issue identified, En:ACT provides:

• The exact transaction and field impacted  

• The specific regulatory rule breached  

• The underlying root cause (data, transformation or logic)  

• The responsible IM or reporting party  

This enables the super fund to:

• Challenge IMs with precision  

• Eliminate ambiguity in discussions  

• Focus remediation on the true source of failure  

Unlike traditional solutions, this is delivered through a fully transparent, glass-box rules framework.  

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5. Structured Oversight and Remediation

The platform enables the client to move beyond monitoring into active control:

• Track issues by manager and root cause  

• Monitor remediation progress over time  

• Identify recurring issues and structural weaknesses  

• Prioritise remediation based on impact and regulatory risk  

This creates a closed-loop control framework, ensuring issues are not only identified, but resolved.

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The removal of ASIC safe harbour created a structural challenge for asset owners:

How to retain accountability without direct control.

En:ACT resolves this by introducing a centralised, independent oversight layer, giving the super fund:

• Full visibility  

• Clear accountability  

• Defensible regulatory control  

The result is a shift from delegated responsibility without visibility to delegated execution with full oversight and control.