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  • Superannuation Administration Group key messages 15 October 2019

    Transfer balance cap indexation

    Helen Morgan provided an overview on the indexation of the general transfer balance cap. Key messages included:

    • The rules around transfer balance cap indexation were included as part of historic legislative changes. Indexation of the general transfer balance cap will occur on 1 July 2020 if the All Groups Consumer Price Index (CPI) figure for the December quarter is 116.9 or higher. This will trigger the indexation of the general transfer balance cap for the first time.
    • The law has always had the distinction between the general transfer balance cap and the personal transfer balance cap. Once the general transfer balance cap is indexed, it will be important for funds to understand the general transfer balance cap will be $1.7million and the personal transfer balance cap will be anything between $1.6 and $1.7million.
    • The ATO is currently looking at system impacts and preliminary business readiness activities in preparation if the indexation does go ahead on 1 July 2020. It is expected the ATO system changes will be deployed in the Quarter 1 (Q1) release (March 2020) however these will have no functional impact until indexation occurs.
    • While the December CPI figure won’t be available to the ATO until January 2020, the ATO is keen to start conversations with industry early due to the complexity of the transfer balance cap indexation.
    • Members discussed a number of scenarios on how the transfer balance cap indexation will apply to individuals in different circumstances, including commencement of their first retirement phase income stream, if they exceed their transfer balance cap, where they may receive a determination and if they have a structured settlement.
    • There will be no new reporting obligations or system changes required for funds, but it is important for funds to consider what messaging and support they might need from the ATO for their members.
    • It was noted that with the ATO Online changes, individuals can now see their personal transfer balance cap, what the highest ever balance was and whether they are entitled to indexation based on the information available.
    • It was also noted that where late reporting and retrospective re-reporting after indexation has occurred, the ATO will be required to go back and re-evaluate the individuals situation including re-evaluating their entitlement for indexation.
    • When the transfer balance cap is indexed there will be consequential changes that will flow through to other parts of the tax and superannuation systems. The defined benefit income cap will also be indexed.
    • Members acknowledged there will need to be significant communication package required to support these changes. Aside from providing website content, the ATO will consider what white paper communications, including call centre scripting can be provided to funds as well as advice for financial planners and tax agents. This will also ensure messaging is consistent.
    • Members were encouraged to provide feedback to the ATO on what information or support the ATO can provide to support their members understand indexation. Members noted the examples provided for the discussion today were useful.

    Protecting Your Super

    Louie Markovski provided an update on the Protecting Your Super (PYS) Package. Key messages included:

    • The introduction of the Treasury Laws Amendment (2019 Measures No.2) Bill into the House of Representatives on Wednesday 18 September 2019 has resulted in the ATO having to reconsider the timing for the proactive consolidation.
    • The Bill contains the amendments to the primary law and regulations in relation to the payment of interest by the ATO. It is expected the legislation should progress through to the Senate without contention to become law.
    • The introduction of this Bill along with the need to implement PYS changes, undertake regression system testing and allow for the aggregation of a new category of Unclaimed Super Money (USM), ‘inactive low-balance accounts’, has resulted in a decision to temporarily delay the rollovers of ATO held USM to funds and the direct payment of USM to individuals from 19 September to 31 October 2019.
    • Members raised concerns that this approach may result in an increase in complaints and suggested earlier communication is required to allow funds to prepare advice and communication to their members.
    • The ATO advised that it will issue a Client Relationship Team Alert (CRT Alert) to broadly communicate the temporary delay of USM rollovers to funds and the payment to individuals.
    • Pending the passage of legislation, the ATO is planning to initiate rollovers of ATO held super including ‘inactive low-balance accounts’ to proactively consolidate to a members active account held by funds from Friday 1 November 2019. Given the expected higher volume of transactions in November, the ATO will be undertaking additional USM aggregation runs on the following dates
      • Friday 1 November 2019
      • Thursday 7 November 2019
      • Tuesday 12 November 2019
      • Thursday 14 November 2019
      • Thursday 21 November 2019
      • Tuesday 26 November 2019
      • Thursday 28 November 2019
    • Any individual requests that come through prior to 1 November 2019 will be managed via a workaround solution.
    • The ATO is currently undergoing testing of the proactive consolidation system solution with a number of test cases that include the interest component, which is calculated at the legislated CPI interest rate, going through the payment variation advice (PVA) process successfully.
    • Members discussed other changes relating to the release of the exposure Miscellaneous amendments exposure draft Bill and Regulations which proposes changes to Superannuation (Unclaimed Money and Lost Members) Act 1999 as well as the exposure draft on Superannuation (Unclaimed Money and Lost Members) Regulations 2019 and how some of these changes will be applied from an administrative perspective.
    • Members were encouraged to provide feedback on the exposure draft on Superannuation (Unclaimed Money and Lost Members) Regulations 2019 with consultation closing 25 October 2019.
    • Members discussed current reporting of inactive low balance accounts and matching account identifiers now that lodgments are done through Member Account Transaction Service (MATS).

    Secretariat note: CRT Alert 051/2019 Temporary delay of USM rollovers to funds and payment to individuals issued on 16 October 2019.

    ATO Online – Total super balance and concessional cap carry forward

    Tim Pulsford provided an update on the ATO Online concessional carry forward screen design. Key messages included:

    • The concessional carry forward updates were included in the ATO Online September 2019 (Q3) deployment.
    • Other changes for the release included SMSF related changes, unused concessional cap screens and the online simulator.
    • There were minimal issues experienced with Q3 deployment. The ATO is planning to provide an update on those issues identified. Members were encouraged to provide any feedback to onlineservicessuperannuation@ato.gov.au.
    • The online simulator is currently going through testing and is still on track to be deployed in October 2019. There is an external communication package being developed to support this release that will include news articles and media releases to provide advice to funds, financial planners and tax agents about the transfer balance cap and what individuals will see.
    • The unused concessional cap screen was a minimal viable product deployed to support the carry forward provisions to provide information that individuals can consume for the 2019–20 year.
    • In moving forward, the ATO will work with industry to develop a solution for the next phase to cover years two to five.

    Kimbra Hutton joined the group and provided an update on the screen designs for this phase which are expected to be made available to industry for feedback in the coming days. Prior feedback from industry has been taken on board to improve useability. Other points to note:

    • The June 2020 (Q2) deployment will be the enduring solution and includes a non-concessional contribution and a concessional contribution screen.
    • Some of the features the screens designs will include
      • a dynamic alert for defined benefit members regarding the different reporting requirements
      • ‘last reported’ and updated dates
      • graphic displays to show how individuals are tracking towards their caps
      • using members information to show when they are close or over the cap
      • including adjustments such as personal super contribution deductions.
    • The ATO will continue to engagement with industry as planning for year's two to five progresses.
    • The ATO will consider how the notice of intent for personal contribution deductions if a member claims a deduction is shown as part of the display.
    • A fix has recently been deployed regarding the display of the Total Super Balance as reported by funds for the 2018–19 year.

    Self managed super funds (SMSF) Rollovers V3 and Release Authorities

    Ian Morgan provided an update on the delivery of SMSF rollovers in the data and payment standard and the digitisation of release authorities from 31 March 2021. Key messages included:

    • The ATO has progressed two design considerations with industry for feedback via the Superannuation and Employment Change Network (SECN)
      • inclusion of a certification value within output of the SMSF verification services (SVS) to advise users if the target SMSF’s Digital Service Provider is using version 3 of the rollover message (industry have supported this feature and will be included in the design)
      • whether the ATO should allow the SVS to be used for verifying an SMSF member prior to a contribution being paid or whether the service remains restricted to rollovers only (this feature requires further consideration and is not expected to be included in the design at this stage).
    • SMSF members aren’t included in any inbound or outbound USM transactions.
    • The use of electronic release authorities will be extended to SMSF members where the DSP is enabled.
    • Updated technical documentation has issued to industry for feedback via the SECN with the build version of the technical documentation expected to be available in November. It was noted the SMSF change log will also be published with the technical specifications.
    • SVS documentation is currently being updated and expected to be released for industry feedback in the coming weeks.

    Secretariat note: An email issued to Superannuation Administration Group members on 17 October 2019 advising the draft version 3 of the Rollover Message Implementation Guide (MIG) and associated technical documents are now available for industry review.

    The ATO online services simulatorExternal Link is now available.

    First Home Super Saver Scheme (FHSSS) Release Authorities

    Reece Parry provided an update on the timeliness and processing for FHSS release authorities. Key messages included:

    • A CRT Alert issued on 9 September 2019 highlighting some performance issues regarding the timely action of FHSS release authorities.
    • Supporting the CRT Alert were some scenarios to assist funds when dealing with issues or unusual circumstances that can arise when actioning FHSS release authorities.
    • It was reaffirmed that as we are dealing with first home buyers, it’s essential that release authorities are actioned quickly to enable the FHSS funds be released particularly in auction situations where strict timeframes are applied.
    • The ATO has reviewed internal processes to look for opportunities to increase efficiencies and streamline and automate the process where possible.
    • There has been positive feedback from funds that they are committed to look for improvements to speed up the process, acknowledging that given it’s a paper based process this can cause some delays.
    • An issue was raised regarding inconsistent addresses being used for release authorities. The ATO is investigation this further and encouraged members to provide feedback and any information when this issue arises.
    • The ATO anticipates doing another data run prior to the end of the year to get a sense of how the process is progressing and encouraged members to raise any issues they encounter through Super CRT.
    • Members raised that it can be difficult based on the current data provided by the ATO to investigate the cause of any late actions without further supporting evidence. The ATO will determine if more detailed information can be provided to funds who continue to have a significant percentage of late FHSS Release Authorities following the next review of data.
    • The ATO is working with the Rollover V3 project team to build a number of audit, fraud and compliance checks at the front end of the system to identify any potential misuse once FHSS are actioned in the data standard.
    • There has been suggestions by funds for the ATO to introduce an interim solution to speed up the FHSS release authority process prior to the implementation of the electronic release process in early 2021, however given that the options available would take around 12 months to implement, as well as decommissioning the current system/process, it is not considered a viable solution.
    • The immediate focus instead will be on implementing improvements to process release authorities as efficiently as possible. It was suggest whether funds could provide release authorities to the ATO via email; however the ATO is unable to accept client information via email. This would also cause potential issues with duplicate processing.

    ATO Identity Security program

    Mark Robinson provided an overview of the Identity Security Strategy, including governance structures and priorities in place to reduce cyber enabled identity crime across the tax and superannuation system. Key messages included:

    • While a lot of work has been done across the ATO to address cyber enabled identity crime, an internal audit recognised the need for an enterprise wide approach.
    • The Identity Security Program was established to ensure a consistent enterprise approach to manage identity security, including the appointment of Senior Responsible Officer, Deputy Commissioner Will Day.
    • The Programs key outcome is to prevent, protect and respond to cyber enabled identity security and identity crime.
    • Members were invited to use the Superannuation Administration Group as the conduit to raise any emerging risks or issues though to the Identity Security Program that might require additional investment or sponsorship.
    • An Identity and Security Strategy has been created which focuses around nine key outcomes. Some of the work being done to support these outcomes includes
      • ensuring the development and maintenance of effective relationships with internal and external stakeholders - the ATO is involved with the Fintell Alliance led by Australian Transaction Reports and Analysis Centre (AUSTRAC) as well as the Inter-bank Fraud Forum and the Australian Competition and Consumer Commission (ACCC)
      • building community resilience including using social media channels to keep the community engaged and alert them to trends with identity security
      • delivering integrated high integrity registration, identity maintenance frameworks, systems and process for example the use of MyGovID and the transition away from AUSkey to Relationship Account Manager (RAM)
      • partner with domestic and international stakeholders, including the Joint Chiefs of Tax Boards (J5) to disrupt criminal syndicates
      • improvements to our identity security and ID crime models to better identify breaches for example through illegal early release to provide a better analytical capability that aims to stop breaches at the front door
      • undertake an integrated intelligence, analytics and monitoring function. It’s important that our partners in the superannuation industry, tax agents and intermediaries help form the big picture about what’s happening in the tax and superannuation cyber security environment
      • pursue appropriate and effective policy and legislative reform, including a submission to Treasury on the review of the Tax Practitioners Board, highlighting the things required to ensure strong cyber security credentials as part of the registration process and any security breaches are reported to the ATO.
    • It was noted if members would like to engage with the ATO further, this can be done via the Superannuation Administration Group secretariat.

    Member Account Attribution Service (MAAS)/MATS snapshot for 2018–19

    Larissa Evans presented a MAAS/MATS snapshot which provided high level overview for 2018–19. Key messages included:

    • The purpose of the snapshot is to share with Superannuation Administration Group members what the ATO has seen in the first year of MAAS/MATS reporting.
    • Members were reminded that the report is for information only and relates to the first year of implementation and is not intended to be a compliance tool.
    • Feedback from members on the report was positive, and that it is an informative summary.
    • It was noted that there have been some shifts in some of the figures provided in the summary since 30 June 2019.

    Fund engagement updates

    Tracy Holloway and Rob Clarke provided an update on fund engagement initiatives. Key messages included:

    • Tracy thanked members for taking the time to provide feedback on the draft Unclaimed Super Monies and Successor Fund Transfer protocol documents. The feedback is currently being considered with the final versions expected to be published in mid-November 2019.
    • Funds may have started to receive email correspondence from Client Relationship Managers regarding the MATS un-linked reports. As the ATO has started to receive the annual balance MATS transactions, funds are reminded to ensure the integrity of the data to enable entitlements to be processed.
    • Members were reminded of the importance to subscribe to CRT Alerts as they are the primary communication used to inform funds of any issues or actions required, particularly in the lead up to the end of October reporting.

    Rob Clark provided an update on the CRT team noting:

    • The ATO welcomes feedback and suggestions for improvements to the CRT service.
    • The CRT team works closely with the CRM teams to share insights on how engagement and services can be improved, particularly to resolve queries at the ‘front door’ and reduce the need to escalate to other areas. There will however be times when further technical or expert advice is required.
    • Areas where funds can assist to reduce delays and reverse workflows includes
      • ensuring there is sufficient information to support the initial query (member details and specific transaction). Members noted there are some privacy restrictions on what member information can be provided. There are a number of alternate platforms that may be an option to correspond information however this requires further investigation
      • when reporting reversionary income streams, there is process to follow regarding opening and closing the accounts of deceased members, the ATO doesn’t necessarily process these in chronological order.
    • It was noted the Superannuation Administration Group provides a good opportunity to discuss insights and observations for any improvements to make engagement between Administrators and the ATO more efficient.

    Action item

    15.10.2019-1

    Due date

    9 December 2019

    Responsibility

    ATO - Robe Clarke, Tracy Holloway

    Action item details

    The ATO to confirm the most appropriate and efficient approach to assist CRT manage the workflow between the ATO and Funds including consideration of alternative platforms

    Tabled papers for noting

    Larissa Evans introduced a number of papers provided to members for noting and information purposes. Papers included:

    • Super Guarantee notifications that will be undertaken during October 2019
    • Information about the Protecting Your Super communication approaches and activities including timeframes and sample notifications to members
    • A report providing insights on the usage of the Employee Commencement service.

    Other business and close

    Tracy Holloway shared some preliminary results from the Australian Prudential Regulation Authority (APRA) fund survey and thanked those who participated.

    The purpose of the survey was to draw out fund preferences on interacting with the ATO. There were 43 responses with some of the key findings being:

    • two thirds of respondents thought that the ATO and funds are working together effectively to administer the super system.
    • agree the ATO provides the right amount of information, however timeliness of communications can be improved and updates on issues being progressed.
    • the ATO website is the most often channel used followed by CRT Alerts and email. This is consistent with funds preference to interact electronically. Call centres were the least used channel.
    • Search ability of the ATO website is an area for improvement.
    • The next survey is expected to run in March 2020.

    No other business was noted. Larissa thanked members for their attendance and contributions.

    Attendees

    Attendees are listed below.

    Organisation

    Members

    ATO

    Larissa Evans (Chair), Superannuation and Employer Obligations

    ATO

    Helen Morgan, Superannuation and Employer Obligations

    ATO

    Ian Morgan, Superannuation and Employer Obligations

    ATO

    Kimbra Hutton, Superannuation and Employer Obligations

    ATO

    Louie Markovski, Superannuation and Employer Obligations

    ATO

    Reece Parry, Superannuation and Employer Obligations

    ATO

    Robert Clarke, Client Account Services

    ATO

    Tim Pulsford, Superannuation and Employer Obligations

    ATO

    Tracy Holloway, Superannuation and Employer Obligations

    AMP

    Grant McPherson

    ANZ Wealth

    David Delaney

    Association of Superannuation Funds of Australia

    Spiros Koziaris

    Bravura Solutions

    Ley Caldwell

    BT Financial Group

    Jimmy Sun

    Colonial First State

    Brett McLeod

    Commonwealth Superannuation Corporation

    Lex Dransfield

    Grow Super

    Tim Coulter

    IOOF

    Heide Stewart

    Link Group

    Mary Gale

    Link Group

    Sue Pearce (Co-chair)

    Mercer

    Narelle Telfer

    National Australia Bank

    Ian Roberts

    QSuper

    Catherine Best

    SuperChoice

    Chris Denney

    TelstraSuper

    Nimalan Puvanasuntharam

    UniSuper

    George Strilakos

      Last modified: 14 Nov 2019QC 60605