1 December 2010

Ms Nisha Kaneyson
Lawyer
Investment Managers & Superannuation
Australian Securities & Investments Commission
PO Box 9827
SYDNEY NSW 2000

Dear Ms Kaneyson

CP140 'Responsible Entities: Financial Requirements'

The Group of 100 (G100) is an organization of chief financial officers from Australia's largest business enterprises with the purpose of advancing Australia's financial competitiveness.

The G100 is concerned about the potential impact of the proposals on the cost and efficient operations of registered managed investment schemes. We believe, that given the nature, diversity and purposes of registered investment schemes, it is inappropriate to require individual managed investment schemes to hold a minimum level of net tangible assets as cash, cash equivalents or other liquid assets as proposed in B4.

The G100 considers that the objective of this proposal can be achieved more efficiently by other means. For example, where a responsible entity manages trusts within the operating structure of a listed entity, say, providing infrastructure, the existence of financial guarantees of liquidity and access to funds within a consolidated group should be permitted as an alternative to physical holdings of cash, cash equivalents and other liquid assets.

The G100 believes that ready access to liquidity is the important consideration in these circumstances.

Yours sincerely

Tony Reeves
National President