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  • SASG minutes 17 May 2017

    Meeting details

    Venue:

    ATO Office, 52 Goulburn Street, Sydney

    Date:

    Wednesday 17 May 2017

    Start:

    10.00am

    Finish:

    2.40pm

    Chair:

    Cathy Cox

    Secretariat:

    Cheryl Ballinger

    Contact phone:

    (02) 4223 2795

    Note: SASG agendas, minutes and related papers are not binding on the ATO or any of the other bodies referred to in these papers. While every effort is made to accurately record views expressed, the wording necessarily represents a summary of statements of general position only, and care should be taken in interpreting those statements. These papers reflect the position at the date of release (unless otherwise noted) and readers should note that the position on any issue may subsequently change.

    Attendees

    Industry

    Andrea Cooper

    Financial Synergy

    Ari Gerasimou

    CBA CommInsure

    Ian Roberts

    NAB

    David Kerr

    NAB

    John Hardas

    Link Group

    Jun Tang

    OnePath

    Sam Finucan

    Bravura Solutions

    Mary Gale

    Link Group - Syncsoft

    Lex Dransfield

    Commonwealth Superannuation Corporation

    Sue Pearce

    Link Group - AAS

    Timothy Coulter

    KPMG

    Tina Cifelli

    AMP

    Kelly Kerr

    BT

    Maria Anislag

    Zurich Australia

    Anthony Steele

    Super SA

    Fiona Galbraith

    ASFA

    Darren Cox

    SA.GOV.AU

    Tania Wilson (for Heide Stewart)

    IOOF

    David Delaney

    ANZ

    Amanda Gunn

    Mercer Australia

    Narelle Telfer

    Mercer Australia

    Erin Quinn (for George Strilakos)

    Unisuper

    Martin Mikulicin

    BT

    Trevin Erichsen (for Matt Pritchard)

    SunSuper

    Anthony Relf (for Louise Hemar)

    Pillar

    William Moy

    CBA

    Brad Ivens

    Ernst Young

    Namphi Nguyen

    Colonial

    ATO attendees

    Cathy Cox

    Assistant Commissioner, Client Services

    Louie Markovski

    Director, Employers & Self-Managed Super Funds

    Shaun Ferabend

    Director, Client Relationships, Intermediaries & Assurance

    Cheryl Ballinger

    Secretariat, Superannuation Administration Stakeholders Group

    Denise Lazarus

    Director, Employers & SMSF's

    Carolyn Harris

    Director, Individuals

    Linda Cheesman

    Director, Funds

    Graham Whyte

    Assistant Commissioner, Technical Leadership and APRA Fund Engagement

    Tracie Crowden

    Assistant Director, SuperStream Program

    Adam Reece

    Super Funds Audience Team

    Annette Thurbon

    Director, SuperStream Delivery

    Mark Barnett

    Director, APRA Fund Engagement

    Helen Morgan

    Super Individuals New Measures

    Sarah Kimmorley

    Super Government Liaison and Consultation

    Frances Sainsbury

    Director, EST

    Apologies

    Heide Stewart

    IOOF

    Sharan Panton

    Link Group - GESB

    Louise Hemar

    Pillar Administration

    Rebecca Scott

    Perpetual Investments

    Matthew Pritchard

    SunSuper

    George Stilakos

    UniSuper

    Marcia Pitstock

    KPMG

    Brett McLeod

    Colonial

    Jayne Pocock

    QSuper

    Agenda items

    1. Welcome

    Assistant Commissioner Cathy Cox opened the meeting:

    • Welcomed all in attendance including new representatives and guest attendees.
    • Accepted that no conflicts of interest were advised.

    2. New measures and outbound letter campaign

    Presented by Graham Whyte

    Appreciation expressed to funds for testing the system and their patience and sharing of information. Update provided on the following:

    • Community and industry are ready for new measures
    • Communications – website, super changes updated weekly (300,000 hits since November 2016)
    • Law companion guidelines (LCG) now final
      • Guidance notes – 15 are drafted with 8 published
       
    • New communication products developed from feedback including:  
      • Improved search ability on ato.gov.au website
      • Alex - Virtual assistant is well versed in Super changes
      • Videos - CPA, Partnerships, Q&A video and 1 x SMSF's
      • Webinars – speeches
      • Correspondence - the letter program will utilise - SMS's
      • Concessional emails - may hold off until July 2017
      • Letter templates provided - Check your super balance – 20,000 emails will commence 20 May 2017
      • Changes to your super balance letter - 23,000 emails
       

    Copies of the outbound letters were provided to the participants. The campaign will be targeting clients that have been identified as possibly being impacted by the super changes.

    Discussion point

    The group discussed the timing of the email campaign where most felt that the emails should commence 1 July 2017.

    Feedback on correspondence is critical and can be sent to the super consultation mailbox or SASG. The letters will be sent via the CRT mailbox between October and mid-December.

    The Death benefit form will be updated shortly following consultation with Industry and feedback.

    PAYG tax guidance notes are finalised and reflect the most current legislation.

    Sarah Kimmorley discussed the new measures and the proposed First home super saver scheme.

    Funds raised the following points for consideration by the ATO:

    • Members may not be contributing to their super savings - Rates of tax - will it be a fixed rate or taxable amount or dependent on taxable income?
    • Will the process be part of the Income tax process?
    • Who will do the calculations and payments - funds or ATO? Will the administration to manage this new scheme be factored in to decisions?
    • Additional reporting and frustration for funds. The extra responsibility for funds was noted;
    • Including higher volumes of release authorities and processes for insufficient account balance. What account e.g. SG contributions?
    • Additional work for funds if the member doesn’t buy a house within six months and the payments have to go back to the fund.

    More consultation will occur with the funds. The ATO will consider all feedback. The frustration voiced by the funds is being heard by the ATO. The ATO holds the responsibility of the scheme and will undertake the compliance work not the funds. There will be some reporting requirements and transitional arrangements.

    New measure: Downsizing eligibility and conditions

    Discussion point

    Funds indicated that given there was no current impact for the funds what will these changes mean for them. Discussion on who would manage the scheme, the funds or the ATO. Points raised:

    • ATO - some people over 65 may not be engaged with the ATO. They may not submit income tax returns and not be in contact with or relate to the ATO.
    • Funds - may have to make significant IT changes to adapt to these changes. If the systems have built in blockers they are concerned about what will occur if only $100 received.
    • Fund - preference would be to advise the ATO when $300,000 contribution limit has been reached. Funds were asked to let the SASG secretariat know if they wish to become part of the consultation process.

    3. SuperStream readiness and implementation update

    Presented by Annette Thurbon

    SuperStream has been working well. Issues have occurred with date of birth. Data standards currently require full date of birth so data fix is occurring behind the scenes. Feedback is required from Industry to advise what they use the date of birth for. Funds will consult with their IT and advise.

    4. SuperStream USM and EPF v2

    Presented by Linda Cheesman

    USM dual channel issue has been encountered when the USI for a destination fund is missing. Main cause of this issue is for when individuals use myGov to rollover money and the client link is established at the wrong level. Fix is due to be deployed for this issue at the end of May.

    Performance issue with our back end aggregation queue (not messaging platform). There has been a failure to process a data message to funds when there are more than 4999 members. Data messages were supposed to have up to 10,000 transactions per message. The ATO needs to reduce this limit in the short term to ensure we can get messages to funds. ATO intends to have in place the 10,000 limit prior to our large contribution runs.

    Discussion point

    Funds were asked whether they could manage a 4,000 member limit in the short term to minimise error message impacts and acknowledged the previous agreed limit of 10,000. It was acknowledged that for example if a fund had 12,000 members that would receive 3 data messages which contained 4,000 messages each and would also receive 3 payments.

    Fund administrator advised that the 4,000 member limit was a big issue for bigger funds who have in excess of 100,000 members i.e. huge number of files and additional risk that the files would reject.

    Linda advised that we had also identified a number of paper PVAs that are being sent to the ATO. If you receive a rollover via SuperStream and you can't accept the payment than you must send an outcome error response message through the SuperStream channel and this will trigger an ePVA. The ATO will be doing some educational work with funds to minimise errors.

    Funds also advised that the number of payment mismatches have increased and the ATO is working to resolve these.

    Funds advised continued frustration with the number of system outages.

    4.2 EPFv2 update

    Recent EPF issues have been resolved and all files have been replaced.

    4.3 BDV - Government contributions v2 (G2B)

    BDV will commence 30 May 2017 and run for a period of 4-6 weeks to allow adequate time to confirm that all government contributions runs and payments as well as recovery processes are working in production. Funds advised that there will be an issue of resources if the ATO delays the cut-off date for contributions and would appreciate advanced notice if a delay is to occur.

    5. SuperStream Business to Government (B2G) reporting

    Presented by Tracie Crowden

    Key messages

    • The ATO will issue S20C in line with current procedures
    • Amendments that require a refund from the ATO are out of scope and will be managed manually
    • We will hold a further workshop with industry over the coming months to walk through and discuss the business processes in more detail
    • The user guide will be updated to reflect any additional information as a result of the workshop and will be published as soon as possible.
    • Lost member reporting implementation guide is being developed as it needs to be fit for purpose.

    5.1 Member Account Attribute Service (MAAS)

    MAAS technical data was published on the SBR website 6 April 2017.

    Industry feedback was received and is being reviewed and new measures need to be included so there was a delay which allowed less time to deploy. A series of technical documents will be sent out to funds but can't be published until one month prior to implementation.

    5.2 Member Account Transaction Service (MATS)

    • To provide greater visibility of a member’s super holdings and in particular their SG payments, the ATO (in partnership with industry) is designing a reporting solution that shifts the current annual reporting to event-based reporting. 
    • This replaces the current annual Member contributions statement (MCS) with transactional level data reported more frequently throughout the year.
    • The Transaction service working group (TSWG) is meeting regularly to develop a solution overview by 30 June 2017 with deployment from 1 July 2018 with an extended cutover period till 1 November 2018.
    • Although a challenging timeframe we consider we are still on target for an agreed solution overview by 30 June 2017.
    • We are starting to send out summary documents to the wider industry and conducted a webinar Tuesday 6 June 2.00pm-3.00pm to talk through the design intent and progress.
    • The pressure points in the design are around amendment reporting and the timeline for industry to capture this granular level detail and report to the ATO in a timeframe that satisfies both the Budget 2016 and STP legislative requirements.

    6. Improving the client experience for super surcharge

    Presented by Louie Markovski

    Surcharge has been an administrative challenge for funds and administrators and whilst the abolition of the tax occurred from 1 July 2005, there is no natural end date to administer whilst members lodge late income tax returns and / or amended income tax returns relating to the 1997 to 2004 income tax financial years. The ATO is asking funds to determine if they are no longer holding members, to send the assessment variation advices (AVA) and funds back to the ATO.

    The General powers of administration (GPA) decision;

    • No longer create new surcharge liabilities. Cease to issue new surcharge assessment and debit amendments which result in an increased liability.
    • Allow credits for previously paid surcharge liabilities to be refunded back to the individual.

    The decision (effective immediately) should deliver benefits to industry, and in the near future, will no longer receive any surcharge assessments.

    August 2017, November 2017 and February 2018 surcharge runs are still scheduled.

    The ATO is also putting strategies together and inviting feedback from funds to assist by emailing SurchargeProjectTeam@atogov.au by 2 June 2017.

    The ATO will be supporting funds and providing regular updates on timeframes and progress, opportunities for consultation and feedback and hold a masterclass on lodging AVAs and data fields.

    7. USM Campaign

    Presented by Carolyn Harris

    The ATO will write to 20,000 individuals in mid-May 2017 and 30,000 individuals in mid-June 2017 focussing on clients with unclaimed superannuation money (USM) held by the ATO on their behalf.

    The ATO will ask individuals to use myGov and link to the ATO to either claim if they are eligible or transfer the USM to their preferred super fund account.

    Funds should be aware that there may be an increase in contact from their members as a result of this campaign.

    7.2 Incorrect member account issue (raised by SunSuper)

    Presented by Shaun Ferabend

    The purpose of this agenda item was to gather input from other SASG members to manage incorrect SG payments from employers to a superfund.

    Discussion

    It was felt that if you as a fund send out a welcome letter to a new member, you need to advise the member before closing.

    7.3 QSQ decommissioning

    Presented by Denise Lazarus

    The ATO is currently decommissioning the Legacy system and has been in contact with funds to endeavour to match the credits in our system with members for refunds.

    The ATO is requesting all outstanding PVAs be submitted as soon as possible and any cheques are cashed on receipt.

    Ari Gerasimou brought up the issue that it has been difficult to locate the missing records to reconcile transactions and requested further assistance from the ATO. It was discussed and acknowledged that some of the transactions were very old and not easy to locate and the ATO will provide more information where possible to assist.

    7.4 Departing Australia superannuation payment (DASP) Working holiday maker (WHM) law

    Presented by Carolyn Harris

    New DASP applications should be available 26 June 2017. This will be a transition process for funds which still have applications on hand. The Department of Immigration has already updated their immigration status.

    Funds have been asked to complete a template which was handed out at the conference. An electronic copy will be going out through the Super CRT mailbox.

    Discussion

    Sue Pearce asked whether the template had to be completed per fund or per administrator. The response was whatever suits your situation.

    Mercer asked whether the Department of Immigration needed to provide more information than the fund uses i.e. the working holiday period is all they need. Additional information was thought to potentially create confusion and errors in processing. This was to be looked at by the ATO. Additionally, would it also be easier to ask the applicant to reapply? It was felt that from an ATO perspective this option was not a favourable one.

    Carolyn Harris advised that we would contact people who have DASP applications over 21 days old.

    7.5 ATO Online and DASP stats

    Presented by Carolyn Harris

    Statistical data presented to SASG members relating to;

    • DASP 2015 & 2016 financial year claim figures
    • Super accounts found by super searches for 2015 & 2016 financial year
    • Direct claims - all products

    8. Update on Risk differentiation framework (RDF)

    Presented by Mark Barnett

    The RDF cornerstones our fund engagement strategy to tailor our interactions based on the results funds receive in their diagnostic report.

    99% of funds are meeting the reporting standards to a good or high standard. This is an improvement of 66% of funds improving their results from last year.

    Favourable feedback has been received from funds and administrators advising that the diagnostic reports help them to improve their data integrity by identifying and disclosing reporting errors and investing in improving their systems and procedures.

    Discussion

    A question was asked whether the ATO is reviewing existing benchmarking and a response advised the ATO is interested in the future high visibility and high resolution data. Graham Whyte advised that the ATO is continuing to improve the APRA web page to include providing all links in the one place.

    Sue Pearce agreed there are many areas where funds and administrators can subscribe to however it is hard to find them. Funds and administrators are more aware of where to look as they engage with the ATO. This information is great feedback for the ATO to bring together collective links. The Service and support page has collective links but feedback is always welcome to help the ATO improve.

    9. Other business

    9.1 Super CRT alerts

    Feedback received from funds is welcome and considered.

    9.2 SOA and GIC

    The Funds and administrators advised that SOAs did not contain enough data or information and the experience was not user friendly. Issues were also encountered when funds and administrators try to identify what account the GIC applies to and why. It was noted that the ATO has a legal responsibility to advise when a GIC liability is imposed.

    Action item: Linda Cheesman to pass on feedback.

    9.3 Release authorities

    Sue Pearce raised the issues of release authorities which include:

    • un-presented cheques
    • sddress issues
    • release authorities going missing

    Sue then asked – Is it a good time to do up a matrix which has been previously discussed?

    Action item: Tracie Crowden to pass on Sue's concerns.

    10. Close

    In closing Cathy Cox, thanked members for their contribution, goodwill and candid approach which are appreciated.

    The next meeting is proposed for Wednesday 16 August 2017.

    Action items

    Item number

    Agenda reference

    Action required

    1

    3

    Feedback required from funds - What do they use DOB information for? Linda Cheesman

    2

    4

    ATO undertaking educational work with funds to minimise errors relating to Superstream

    3

    5

    Further workshops with Industry over coming months to walk through and discuss Superstream Business to Government processes in more detail

    4

    5.1

    MAAS Framework and documentation to be sent out to funds as soon as possible - Tracey Crowden to come back to the funds

    5

    6

    ATO to provide opportunities for consultation and feedback and hold a masterclass on lodging AVAs and data fields.

    6

    6

    Funds to assist by providing feedback on ATO strategies being developed for streamlining the AVA process. Surcharge

    7

    7.3

    Funds are asked that all outstanding PVAs be submitted as soon as possible and all cheques cashed

    8

    7.4

    ATO to review the volume of information supplied by the Department of Immigration to funds

    9

    7.4

    ATO to contact people who have DASP applications over 21 days old

    10

    9

    Linda Cheesman to pass on feedback for SOAs. Funds want more information included particularly in regards to GIC

    11

    9

    Tracie Crowden to pass on concerns and issues relating to Release Authorities - Forum

      Last modified: 22 Sep 2017QC 53361