With the release of the final forms of APRA APS 510 (Governance) and APS 520 (Fit and Proper) we now know what APRA expects of authorised deposit-taking institutions in excess of the requirements of the ASX Principles which apply to listed public companies.

So if you are affected how do you make the transition and when do you have to comply by?

APS 510 will apply from 1 October 2006.

However if the entity is unable to comply immediately with particular requirements in the Prudential Standard, due to the need to amend its Constitution it must notify APRA, in writing, prior to 1 October 2006, providing details of the next scheduled meeting of members that will approve the necessary changes, in which case those particular requirements do not apply to the entity on 1 October 2006. In any event, those requirements will apply to the entity not later than 31 March 2007 (APS 510.62)

APS 520 will apply from 1 October 2006.

A fit and proper assessment must be completed for each responsible person by 28 October 2006 (APS 520.25)

The entity must, by 28 October 2006 notify APRA of the following information for each responsible person:

(a) the person’s full name;

(b) the person’s date of birth (for identification purposes only);
(c) the person’s position and main responsibilities; and

(d) a statement of whether the person has been assessed under the Fit and Proper Policy. (APS 520.40)

The starting point is a "gap analysis": look at what is required, what you have already done and what remains to be done. that will give you an action plan for the development of policies and processes.