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  • Superannuation Administration Group key messages 9 December 2019

    Update on action item 15.10.2019-1

    Rob Clarke provided an update to the action item in regards to Super Client Relationship Team (Super CRT) managing workflows between ATO and funds. Key messages included:

    • The conversation continues within the ATO to find a suitable client services platform solution. There will be further updates provided as these investigations progress.
    • Overall volumes of queries on hand in Super CRT are under control heading into Christmas, with total queries overall decreasing compared to this time last year.
    • Action item 15.10.2019-1 is closed.

    Protecting Your Super

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

    • As of 21 November 2019, consolidation has been successful with$2.07 billion reunited with members. This does not include batches rectified between 26 November and 5 Decembe 2019.
    • There have been some issues with reporting including some files being returned for 21 November and 26 November 2019. The ATO are rectifying the issue with relevant funds.
    • There will be a final run for 2019 on 10 December. This will include 76,000 accounts to be consolidated. The ATO will contact funds prior to the run and provide an update on what to expect.
    • There is a possibility of an additional run on Thursday 12 December 2019 to ensure as many payments as possible issue prior to Christmas. More information will be known and distributed to funds after the 10 December event.
    • Industry advised that they are anticipating the April 2020 Unclaimed Super Money (USM) run to be significant in size due to insurance cancellations and questioned whether hyper-care arrangements will be in place. The ATO will work with industry to understand volumes to be expected in comparison with April 2019 run, and manage these accordingly.
    • Industry requested clear communication be issued in relation to deferral policy in light of the next major USM run.
    • Industry requested updated guidance, in particular on genuine errors and adjustments. Scenario based guidance would be of most use.
    • There will be a Protecting Your Super post implementation review early next year. Topics such as adjustments and cancellation requests and how incorrect files impact industry will be included.

    Secretariat note: In reply to Jimmy Sun (BT Financial), regarding proposed legislative changes to the inactive low-balance account (ILBA) declaration/election Treasury Laws Amendment (2019 Measures No.3) Bill 2019 introduced into Parliament on 5 December 2019 amends the exception to the definition of ‘inactive low-balance account’ so that the member makes the election directly to the superannuation provider rather than the Commissioner.

    If the proposed amendment passes into law, there would not be a requirement for the fund to tell the Commissioner the member made an election – it is just something the funds needs to consider in determining if an account is an ‘inactive low-balance account’.

    Annual Balance Reporting - summary and reflections

    Tracy Holloway provided an update on Annual Balance Reporting. Key messages included:

    • ATO estimated 26 million in annual balance reports to be made, and 27.5 million reports were actually received by funds. This was a smooth and seamless process from an ATO perspective. Industry was generally supportive that the process went well, including noting that it was the Member Account Transaction Service (MATS) transitional year which added complexity for members and funds getting used to new products and processes.
    • To clarify point 10(b) of the paper on Annual Balance Reporting, a fund is required to report a zero dollar balance if the fund is not reporting a balance at all regardless of the type of super interest. When amending your MATS annual obligation (i.e. the Member Contribution Balance Amounts labels on the MATS) you must complete all fields. As per the MATS Business Implementation Guide (BIG) the two fields 'Balance date' and 'Account balance' are mandatory and consequently cannot be left blank, even if you are amending one of the other fields. The 'Phase value amount', 'Phase type code', 'NTC' and 'DBC' fields are optional – meaning if you have to report you must complete them. But if you have nothing to report the form will still make it through our systems. If you are amending an annual MATS you must complete all the fields again, not just the one you need to change (because otherwise it will input a $0). See below table for an example.

    Original

    Amendment

    Balance date: 30 June 2019

    Balance date: 30 June 2019

    Account balance: $150,000

    Account balance: $150,000

    Phase value amount:

     

    Phase type code:

     

    NTC: $30,000

    NTC: $40,000

    DBC:

     

    • To clarify, point 11 of the paper on Annual Balance Reporting is to remind those funds that are Defined Benefit (DB), because the account balance field is mandatory, a value must be put in here. In some cases, where it is a DB interest and they are reporting notional taxed contributions (NTC) and/or defined benefit contributions (DBC), the applicable value may be $0.
    • ATO discussed feedback with industry for end of year processing. Industry members were concerned about any prospect of moving the date for end of year processing to earlier than 31 October each year because their systems have already been built on that schedule. There was also recognition that there are generally two different business processes for ATO reporting and member statements.
    • It is unlikely industry will need to provide orchestration estimates of their annual reporting volumes and dates next year, as was required this year - the first year of this reporting.

    Reporting protocols updates

    Tracy Holloway provided an update on reporting protocols. Key messages included:

    • ATO has not yet issued the Annual Member Contribution Balance Amounts protocol for consultation. It will be available in January 2020 with four weeks for industry to review.
    • The recent reporting process provided ideas for restructuring and clarifying the Annual Member Contribution Balance Amount protocol chapter including accumulation content. This will be up on Let’s Talk for consultation early in January for four weeks. Industry supported this as a reasonable timeframe.
    • USM protocol document has been updated and will be almost identical in terms of technical content to the guidance previously issued out for consultation.
    • ATO advised that amendment content is being relocated in the protocol into the product chapters rather than keeping it together in an amendment chapter, as this reflects intuitive user experience. Industry suggested the ATO include as many references and links to amendment content as possible throughout the protocol.

    Action item

    09.12.2019-1

    Due date

    6 January 2020

    Responsibility

    ATO - Tracy Holloway

    Description

    ATO have received technical guidance as part of Successor Fund Transfer (SFT) protocol update. When an account is received by a fund through a SFT, the clock restarts whether the SFT has occurred within the same trustee and the clock restarts for all unclaimed types. Industry questioned this as it has significant impact for them. Technical advice to be circulated to Superannuation Administration Group (SAG) members.

    Secretariat note: Action item has been closed. Advice has been emailed to SAG members. It was noted if members would like to engage on this topic further they can do so via the SAG secretariat.

    SuperMatch campaign

    Shane Moore provided an update on the SuperMatch campaign. Key messages included:

    • There are no technical changes to the terms and conditions of use in Version 8 compared with Version 7. As part of the SuperMatch campaign, the ATO will be issuing letters in December 2019 to all trustees as well as an alert to say Version 8 has been issued. A response is required by mid-February 2020 from those that have not yet engaged on a solution compliant with Version 7 or 8.
    • If a trustee fails to engage with the ATO by the deadline they will have their permission to use the service removed. It should be noted that permission to use the service is controlled by the ATO at the ABN level, so all solutions connected to the Trustee’s ABN will lose access to use SuperMatch where permission is removed.
    • As part of the SuperMatch campaign, trustees can write in for assurance they are compliant under Version 7 or Version 8.
    • Administrations can engage on behalf of their client base as long as the general solution is the same.
    • ATO will be holding webinars on SuperMatch in January and February 2020 to inform stakeholders with a focus on best practice.

    AUSkey transition

    Joe Maxymenko provided an overview of the AUSkey transition. Key messages included:

    • AUSkey will be decommissioned by the end of March 2020. The runway is short. Industry has been encouraged for a while to begin their preparation if they have not already. The AUSkey transition team is available to assist funds and administrators to prepare for this change.
    • ATO is hosting a webinar Friday 13 December 2019 for stakeholders. It is noted that information will be in relation to the business impact, not a technical advice forum.
    • ATO use of IP1 (previously described as IP1+ or addressed as exception handling for those individuals who cannot provide Australian documents used for IP) will be delivered in the Quarter 1 (Q1) release in mid-March 2020.
    • Further webinars held by ATO will cover making a claim for an individual already sitting on ABR, and how that relationship will be established.

    Large APRA fund extract (APEx)

    Karen Stacey provided an overview of the Large APRA fund extract (APEx). Key messages included:

    • As the transition to Event Based Reporting progresses there has been a shift from annual reporting to event based, and a change in focus from compliance to engagement; as a result the current risk differentiation framework (RDF) process is no longer appropriate.
    • ATO held an industry working group to collaborate on a new contemporary high level design for a periodic extract. The group identified 10 metrics that would add value to the industry.
    • Industry highlighted the need to communicate the shift from compliance to engagement, and recognise that the move to self-assessment will be a bigger shift for some funds more so than others – but is considered a better outcome.
    • The APEx engagement tool will aim to
      • provide funds with information to self-assess their operational or reporting performance and identify opportunities for improvements
      • provide ATO with information to identify areas of focus for further direct fund or industry wide engagement and support.
       
    • ATO will develop an APEx prototype for consultation with our external working group early in the following year, and will then provide an update to the SAG.

    2020 - priorities moving forward

    Sue Pearce opened discussion on priorities moving forward for 2020. Key messages included:

    • Moving forward into 2020 it was noted that early visibility of initiatives and changes coming would be beneficial for funds. This included items like
      • lead in time for rollover Message Implementation Guide (MIG) V3
      • early visibility of items on the Super Changes Roadmap
      • any changes upcoming to Member Account Attribution Service (MAAS)/MATS
      • futureproofing changes being made currently.
       
    • Important topics that industry would like to touch on in 2020 are
      • budget changes and how ATO and industry can work together
      • updates from the Rollover working group (in regards to administration changes)
      • attributes of release authorities within MAAS to increase functionality
      • risk in context of administrative processes
      • AUSkey transition outcomes
      • closed account remediation, clarity around that formal process and where it impacts the ATO
      • data migrations (not always SFT), guidance and updates on how ATO records are being updated and if they are accurate
      • USM April 2020 process
      • emerging technologies (New Payment Platform [NPP] and Block-chain)
      • regulatory obligations
      • updates from APEx data.
       

    Tabled papers for noting

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

    • ATO online - update
    • SMSF Rollovers and Release Authorities - update
    • End of year system shutdown period – CRT alert 056/2019.

    Attendees

    Attendees are listed below.

    Organisation

    Members

    ATO

    Larissa Evans (Chair), Superannuation and Employer Obligations

    ATO

    Ian Morgan, Superannuation and Employer Obligations

    ATO

    Joe Maxymenko, Superannuation and Employer Obligations

    ATO

    Karen Stacey, Superannuation and Employer Obligations

    ATO

    Louie Markovski, Superannuation and Employer Obligations

    ATO

    Robert Clarke, Client Account Services

    ATO

    Shane Moore, Superannuation and Employer Obligations

    ATO

    Tracie Crowden, 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

    CommInsure

    Geoff Ferguson

    Commonwealth Superannuation Corporation

    Lex Dransfield

    Grow Super

    Tim Coulter

    IOOF

    Heide Stewart

    Link Group

    Mary Gale

    Link Group

    Sue Pearce (Co-chair)

    Mercer

    Amanda Gunn

    National Australia Bank

    Ian Roberts

    QSuper

    Catherine Best

    SuperChoice

    Chris Denney

    TelstraSuper

    Nimalan Puvanasuntharam

    UniSuper

    George Strilakos

      Last modified: 20 Dec 2019QC 61040