Behind the constant stream of communication sit two obligations most funds underestimate. Every message has to be accurate, and every dollar behind it has to be a defensible use of members' money.
Two duties on every claim and every dollar
How you spend
Since 2021, the SIS Act has required trustees to act in members' best financial interests, and it flipped who has to prove what. It used to be the regulator's job to show a fund had misspent members' money. Now it's the fund's job to show the spend was justified, with documentation, whenever asked. A campaign is members' money, and the fund has to be able to stand behind it.
What you say
ASIC regards it an offence to make false or misleading representations about a financial product. That covers what an option is called, what your website says it holds, and what you claim about fees, returns or green credentials.
So every piece of content a member sees has to answer two questions: Is the claim accurate? And can the fund show the money behind it was well spent?
The communication never stops
A fund reaches members somewhere almost every day: ads for prospective members, retention campaigns, statements, emails, and app notifications. Every one carries claims about returns, fees or how an option is invested.
The real risk in that is huge: things get missed by the human eye. A stale return figure, an old disclaimer, a description that no longer matches how an option is managed - a wrong line slips through and gets copied into every asset built from the same template before anyone notices.
Route all of that through a manual review queue and it causes even more problems.
Your most expensive people end up doing your cheapest work. Compliance lawyers and analysts spend their days checking disclaimers, risk warnings and fee tables, the mundane, repetitive work that could be automated.
And you stop getting value from your tools. If AI produces content in minutes but each piece then waits in a review backlog, you've moved the bottleneck, not removed it.
ASIC is checking what funds publish
In September 2026, ASIC issued six infringement notices totalling $118,800 to three fund trustees over misleading representations about investment options found during a review of fund websites:
AMIST described an option as invested entirely in private equity when international shares were more than 40% of it.
ART's member portal said an option was 100% unlisted assets and alternatives when about 5% sat in listed holdings.
Telstra Super's website showed the wrong time horizon and asset mix for a property option.
Plus, over the past two years the regulator has secured a run of greenwashing penalties in the millions: Mercer ($11.3m), Vanguard ($12.9m) and Active Super ($10.5m) across 2024 and 2025.
Smaller slip-ups that once passed unremarked now draw notices.
The solution: reviewing content at pace
The funds handling members' communication well check content at the speed they publish it.
Let software cover the reviews before and after launch
Automated review catches the small changes that cause the big problems: a bad edit, an old disclaimer, a return figure that's slipped out of date. It also clears the queue, so marketing isn't waiting on legal.
Reserve your experts for real risk
Let software handle the routine checks and give legal and compliance the high-risk judgment calls that need a human eye.
Keep the record
The onus of proof sits with the fund, so every check and decision has to be written down and easy to explain. When a regulator asks about a claim from two years ago, "we looked at it" won't do. A record of what you checked, and against which rule, will.
Use tools built for super
Best financial interests, misleading conduct, design and distribution, greenwashing, anti-hawking: each needs its own check, not one pass over everything.
Key takeaways
Constant member communication is how funds compete now, and AI is only speeding it up. Every message has to be accurate and a defensible use of members' money, and periodic review can't keep up. The gap between what a fund has published and what it can defend widens every week, while enforcement keeps landing on ordinary marketing on everyday channels.
Haast checks everything your members see before and after it goes live, from website and social media, to affiliate content. Marketing runs at full speed, legal and compliance stop babysitting disclaimers, and every check maps to the rules a super fund actually has to meet, with the record to prove the work, inside the tools your teams already use.
See how it works: marketing compliance for financial services, or book a product tour.
Team Haast


