Noel Davis is right. Super funds are not a magic pudding for trustees (and APRA) to cut a slice from if they are unable to conduct themselves effectively. APRA should have required trustees to stump up the 'reserve' funds in the first place, over perhaps a longer time. If that required trustees to increase fees then that's just the way the market works - to stay competitive they might have had to introduce some offsetting real efficiencies.