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  • SASG minutes 21 March 2018

    Meeting details

    Venue: ATO Office , 52 Goulburn Street, Sydney

    Date: Wednesday 21 March 2018

    Start: 10.00am

    Finish: 2.05pm

    Chair: Robert Drummond

    Secretariat: Shaun Ferabend

    Contact phone: (07) 3121 7466

    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

    Name

    Organisation

    Andrea Cooper

    IRESS

    Dianne Sherry

    IRESS

    Ari Gerasimou

    CBA

    Daniela Palermo

    CBA

    Erin Quinn

    Unisuper

    George Strilakos

    Unisuper

    John Hardas

    Link Group

    Louise Hemmar

    Mercer Australia

    Narelle Telfer

    Mercer Australia

    Sam Finucan

    Bravura Solutions

    David Delaney

    ANZ

    Edwins Fung

    ANZ

    Fiona Galbraith

    ASFA

    Catherine Best

    QSuper

    Tina Cifelli

    AMP

    Ian Roberts

    NAB

    David Kerr

    NAB

    Sue Pearce

    Link Group

    Zain Dom

    Link Group

    Mary Gale

    Link Group Syncsoft

    Jun Tang

    OnePath

    Martin Mikulicin

    BT Financial

    Maria Anislag

    Zurich

    Tania Wilson

    IOOF

    Mary Low

    Colonial First State

    Darren Cox

    Super SA

    Lex Dransfield

    Commonwealth Super Corporate

    ATO Attendees

    Name

    Role

    Robert Drummond

    Assistant Commissioner, Client Account Services

    Shaun Ferabend

    Director, Client Relationships, Intermediaries & Assurance

    John George

    Director, Project Lead – Budget Measures and Change Implementation

    Tracie Crowden

    SPR SS Reporting to Government (B2G) Project

    Cathryn Hummel

    A/g Assistant Commissioner, SPR Individual Client Engagement

    Louie Markovski

    Director, Super Individuals Super Experience

    Kylie Smith

    Director, APRA Fund Client Experience, Client Engagement

    Frances Sainsbury

    Director, Application Architecture & Design

    Graham Whyte

    Assistant Commissioner, SPR Tech Leadership and Advice

    Chitra Pradhan

    Director, APRA Fund Engagement

    Helen Morgan

    Director, Inds New Measure Project

    Ty Winmill

    Director, SPR STP SS Data Standards Service

    Loretta Green

    Assistant Director, Client Account Services, Client Relationship Team

    Cheryl Ballinger

    Business Analyst, Client Account Services, Client Relationship Team, SASG Administration

    Apologies

    Name

    Organisation

    Heide Stewart

    IOOF

    Amanda Gunn

    Mercer

    Kelly Kerr

    AMP

    Jayne Pocock

    QSuper

    Matt Pritchard

    SunSuper

    Timothy Coulter

    KPMG

    Maria Pitstock

    KPMG

    Elissa James

    CAB

    Rebecca Scott

    Perpetual

    Agenda items

    1. Welcome

    Director, Client Relationships, Intermediaries & Assurance Shaun Ferabend opened the meeting:

    • Welcomed all in attendance including new representatives and guest attendees.
    • Acknowledgment of the traditional owners and custodians of the land.

    2. Small Business Superannuation Clearing House

    Presented by Cathryn Hummel

    On Monday 26 February the SBSCH moved from a platform administered by the Department of Human Services to become part of ATO online services.

    SuperStream messaging in relation to Member Registration Requests and Contribution Transaction Requests were not reaching their respective destinations. Regular CRT alerts are being provided to keep funds informed whilst IT fixes are being deployed.

    Some users have experienced difficulties with the security authentication options of AUSkey and Manage ABN connections and we have provided additional support.

    Funds should have their credentials in place before April 2018.

    CRT alerts will be issued once more is known about the issue.

    3. Compassionate release of superannuation

    Presented by John George.

    John George and Susan Layoun joined the meeting for this agenda item.

    John reported that Legislation supporting the transition of this measure from DHS to the ATO was introduced into Parliament on 7 February 2018, and passed the Lower House on 27 February 2018. It is expected to be tabled in the Upper House over the coming weeks. The associated Regulations were exposed for public consultation on 21 February and submissions close on 23 March. Following this, Treasury intend to progress the transition to an Executive Council meeting for Royal Assent.

    In terms of a proposed transition effect date, this will largely be subject to both the timing of these legislative processes and agreement between DHS and the ATO. At this point in time, both agencies are aiming for 1 July 2018 as the earliest possible date, subject to the abovementioned legislative processes. We are expecting to have more certainty on this date over the next month, and will be communicating this to industry as soon as this has been confirmed.

    John reported that the eligibility, rules and other provisions of this scheme will be largely unchanged under this transition. However the ATO will provide the following enhancements for individuals:-

    • aligning this service to the ATO individuals superannuation portal within myGov allows for individuals visibility of all their super accounts
    • the ability for individuals to upload accompanying documentation simultaneously with their application (this is currently a '2-step process' in the DHS regime)
    • sometime in the period after transition, our ATO web content will have an eligibility tool that quickly and easily allows individuals to determine if they can apply and what evidence they will need
    • streamlining of the existing four separate DHS paper application forms into one combined application form for all conditions of release.

    From a fund experience perspective, there is a new provision in the Regulations that will allow for the ATO to provide copies of approval notices to funds at the same time as the individuals. This is designed to further mitigate potential for fraud and negate the existing need for funds to ring the ATO. Industry representatives at the meeting were provided with a paper copy of the current version of the ATO notice. An electronic version of this notice and the member approval letter will be circulated once the legislation and Regulations for this transition receives Royal Assent.

    John reported that in previous consultations, industry overwhelmingly agreed that the following fields are required by funds so that when an individual approaches the fund for the release, they can use this notice to validate and act upon this request:-

    • Member Name
    • Member Account Number
    • Amount of Release approved by the ATO
    • Unique Superannuation Identifier (if known).

    Funds also indicated a strong preference to receive a separate notice for each account that has been selected for a release approval.

    In terms of the preferred mechanism for funds to receive these notices, industry overwhelmingly agreed that the existing BDE process currently used by funds to receive other ATO notices is the strong preference for the short to medium term.

    For the longer term, it is recognised that both the ATO and industry are keen to streamline and digitalise all ATO 'Release Authorities' into the future. It is however recognised that the Compassionate release notice to the fund is not a 'Release Authority'. The other consideration is that 'Release Authorities' require the funds to send back a 'response' to the ATO. Again, for Compassionate release notices, there is no response needed by the funds to the ATO.

    In the ensuing discussion, there appeared to be general agreement that these notices should form part of the 'broader Release Authority' suite when that project is realised (currently slated for late 2019). The meeting also favoured the concept of this notice requiring a response from funds to the ATO by way of an 'immediate receipt acknowledgment' (as opposed to waiting for a member approach prior to responding).

    Sue Pearce asked the ATO to confirm whether the proposed short-medium term BDE process for these notices will work on the basis that funds will be prompted about incoming notices automatically, or will they have to regularly monitor their mailboxes. The ATO agreed to confirm this process and include it in the meeting minutes.

    Action item

    ATO (John George) to confirm details of the mechanism for funds receiving these notices, including whether funds will be prompted about incoming notices automatically, or will they have to regularly monitor their mailboxes.

    • Present at next SASG in June an overview of the process.
    • Provide a copy of the member version of the approval letter with contact details provided.

    Post meeting response to action item

    The mechanism for funds to receive these ATO Compassionate release notices will be via the BDE service that was also previously used by funds to receive Electronic Portability Form (EPF) requests from the ATO. From 1 July 2018, funds should automatically receive compassionate release email notifications. Funds will need to go to the File Status page of this service to view and download the Compassionate release PDF notice files. Funds will need to ensure that the appropriate permissions are in place for staff to view these files. This can be set in Access Manager by the Funds’ AUSkey administrator.

    Funds questioned whether it is a legal requirement for them to act upon this new fund notification letter from the ATO to release money directly to the client. John responded that this notice is purely a record for the fund to store for the purpose of validation when/if the member presents their approval letter to the fund. Under the existing DHS administered scheme, funds wait for the member to bring their approval letter to the fund before they start processing this release. This transition to the ATO and the fund receiving an ATO notice does NOT change this practice. The proposed Regulations do not mandate any obligation on the provider to release funds based on this new notice. John reported that from consultation discussions, some funds may want to proactively adopt this process, and if so, this is a question for the funds internal compliance areas to pursue. DHS have indicated that historically, applicants’ circumstances sometimes change and they may decide not to pursue a release after an approval has been made.

    John also indicated that the ATO will be looking to publish the pertinent questions/answers from a fund perspective (similar to the content discussed in this meeting), via the ATO’s Let’s Talk platform, once the legislation and Regulations for this transition receives Royal Assent.

    John also took this opportunity to bring industry attention to the DHS free electronic service called Centrelink Confirmation eServices (CCeS) in respect of scheme that allows for early access of superannuation due to financial hardship (administered by DHS). John pointed out that this CCeS service can be used by super funds, with the person’s consent, to immediately confirm if a person meets the income support requirements of early release for financial hardship. Around 30 super funds and administrators are using CCeS at the moment. The service is quick and efficient, saves time and paperwork, and reduces the risk of fraud. It allows funds to electronically confirm information with DHS directly, so that trustees can make a decision on the person’s early release application faster. John provided industry participants with a paper copy of the DHS flyer, with an electronic copy to be attached the minutes of this meeting.

    See also:

    Centrelink Confirmation eServices (CCeS) for businessesExternal Link

    4. Superannuation housing measures

    4.1 First Home Superannuation Saver Scheme (FHSSS)

    Presented by John George

    Industry representatives at the meeting were provided with a paper copy of the current version of the ATO FHSSS Release Authority Statement (RAS) notice. The project team have incorporated some suggested changes that were made at the Housing Measures Consultation sub group meeting in mid-March. Feedback was encouraged during the meeting. John then covered a range of questions and answers received from funds to date on the FHSS Scheme. These will be published shortly via the ATO’s Let’s Talk platform.

    4.2 Downsizing

    Presented by John George

    John George also spoke to this agenda item on behalf of Julie Rowland (the Project Lead for this measure).

    Industry representatives at the meeting were provided with paper copies of the current version of the ATO downsizer approved form and accompanying instructions. John recapped that where a member chooses to make a downsizer contribution, this choice must be in this approved form. This form is given to the super provider (not the ATO) either before or at the time they make the contribution. Both the approved form and accompanying instructions will be accessible via on ato.gov.au and available to download from mid-June 2018. As it is in the approved form, third parties can create their own form; so long as it contains all the required elements. The project team have incorporated some suggested changes that were made at the Housing Measures Consultation sub group meeting in mid-February. Feedback was encouraged during the meeting.

    John then reported that the ATO is still intent on having the ATO Online Portal option available by 1 July 2018. However, given the short time frame for this delivery, there is still a risk that that the Portal Solution may not ready for implementation prior to this date. As such, the ATO are progressing the option of a contingency process to be available and in place for 1 July 2018. This proposed mitigation is a phone based solution where funds will be able to call the ATO to report any downsizing contributions. Industry participants expressed that they were hearing mixed messages on whether the Online Portal option is proceeding. The ATO responded that a more certain position and decision will be communicated over the coming 1-2 weeks.

    Industry also indicated that most funds will not be cutting over to reporting via MATS progressively until April 2019, and as such, suggested that they should be deferring the reporting of their Downsizer contribution reporting until they have this capability. The ATO acknowledged this concern and agreed to pursue a response with the project team for inclusion in the minutes of this meeting.

    Action item

    ATO (John George) to obtain a response to industry concerns on the timing commencement for Downsizing reporting

    Post meeting response to action item

    The project team encourages funds to utilise the concept of real time reporting when they receive a downsizing contribution (either via the Online Portal or phone). This has the following benefits for funds and members:

    It will save funds time in that once funds are 'MATS ready', they may have a large backlog of downsizer contributions to report through the portal or by phone, which could be very time consuming.

    Reporting each downsizing contribution in real time minimises the risk of any downsizer contributions not being processed, and any potential reverse work flows for both funds and the individual down the track.

    For members, it minimises the likelihood of downsizing contributions being reported as non-concessional contributions and not adjusted through the portal/phone solutions, which may result in individuals being assessed for Excess Non-Concessional Contributions. We acknowledge that the decision on how to report downsizing contribution rests with funds, but as outlined above, we would recommend funds adopt real time reporting.

    5. Large Fund Diagnostic Reports

    Presented by Chitra Pradhan

    Findings of current RDF process and delivery of the 2017 diagnostic reports overview was provided.

    We will continue to engage with funds to provide support in improving reporting performance amid the challenges of on-boarding onto the new event-based reporting platform.

    A webinar will be held in April with fund trustees and administrators to discuss the information contained in the diagnostic report and overall results for the industry.

    We are in the process of redesigning the diagnostic report and are consulting with internal stakeholders.

    We value feedback provided by industry and will invite funds and administrators to provide comments and suggestions in relation to the design of the 2018 process and the report itself.

    Administrator reports will be provided to some funds. Funds can request administrator reports if required.

    6. APRA Fund Communications Reference Group

    Presented by Kylie Smith

    Update provided.

    Positive feedback received from the group about this initiative.

    • Timing of the combined monthly SuperNews is the first or second Thursday of the month

    Discussion

    Discussions outlined that communication between the funds and the ATO is the key to successful interactions. An issue was discussed that the Let's Talk webpage is cumbersome as there is a need to re-register twice which may not be obvious to users.

    Action item:

    • SuperNews, add to minutes on how to subscribe and attach the flyer.

    7. Surcharge May final run; DASP enhancements; USM - ATO outbound campaign

    Presented by Louie Markovski

    7.1 Surcharge - May final run

    Improving the client experience project for surcharge is almost complete. Over the next two months:

    • process final AVAs for the last surcharge run in May 2018
    • finalising a process to return credits to individuals. We are currently testing the legacy system to ensure that all future credits post 1 July 2018 are sent to individuals rather than the fund (with the exception of UDBF members)
    • also a solution for those who may wish to return credit to their fund - if they have not retired.

    Fund feedback on the project:

    'The super surcharge project team has been amazing at assisting funds work through issues and reconciliations'.

    7.2 DASP - Enhancements for funds - March 2018 implementation

    DASP – new online search functionality will be deployed 24 March 2018. Funds will be provided with an instruction guide.

    The ability to self-serve, search and locate applications means the ATO will no longer be required to send a copy of the application via an unsecured email channel.

    7.3 USM - ATO outbound campaign

    An outbound campaign is schedule to commence in early April 2018, notifying 100,000 individuals via email, SMS and letter, that the ATO is holding USM that belongs to them.

    The priority April 2018 schedule is as follows:

    • 40,000 emails to myGov registered individuals (not previously contacted)
    • 40,000 emails to individuals not registered with myGov
    • 10,000 paper letters to individuals with no email address (not myGov registered)
    • 10,000 SMS to individuals with only a valid mobile number (not myGov registered)
    • 80,000 follow up SMS to individuals that have been sent an email

    Candidates selected will be over the age of 18 and under the age of 65 years.

    8. TBAR reporting

    Presented by Helen Morgan

    System release happening next week – with assessments issuing in April:

    • ETB assessments to individuals who exceeded the cap and then brought themselves under the cap
    • Child death benefit dependent assessments.

    System commutation authorities are likely to issue in April. It is not expected to be large volumes. If funds consider a commutation authority looks incorrect, contact the CRT mailbox.

    TT18 includes a change to the individuals label for capped defined income stream and the online calculator.

    Funds are reminded, that if engaging in SFT, please let the ATO know to minimise the impacts on members with an ETB.

    9. SuperStream 20C Notices; MAAS and MATs Workshop Updates

    Presented by Tracey Crowden

    9.1 SuperStream 20C Notices

    Deployment was successful for most funds.

    Discussion

    A technical receipt will also be issued regardless of the pattern – this will give funds evidence that they have met their reporting lodgements.

    Intermediate (validation and business response in the one message) and delayed response (validation and business response will be provided in two messages). For batches, all errors will be contained in the one message.

    Business Implementation Guide (BIG) will be out by Easter.

    File size:

    • Pre July – 10,000 records for each batch – if funds want to send concurrent batches, contact ATO to discuss.
    • Post July – we can deal with concurrent messages – no need to contact ATO – limit will be 100,000 in each batch. Testing is being undertaken on 200,000 limits.

    Action

    Confirmation required by funds on how regularly they can lodge after July.

    9.2 MAAS and MATS - Workshop updates

    The deployment of MAAS is due within the next few weeks.

    Discussion

    Questions were asked about a TFN update as a MAAS event, ie is it an update or a MAAS open/close event?

    If no TFN and you get a new TFN reported – this is an update

    If you have a TFN that has been matched, but for whatever reason you get a new TFN that is matched – how is this reported?

    Funds questioned how this issue had been referenced in the protocol guidance.

    Version 1 of the Q&As have been published, rolled into common questions. These will be updated fortnightly with version control (indicating a new question or update to previous question).

    Version 2 of the foundation data handbook has been published.

    An issue was raised about the reconciliation process with foundation data ie number of members a fund has and the number the ATO has on record with the fund.

    Account opened date is an important field. The actual date the account was opened will allow for the ATO to system fix and add an extra field for status update date.

    If you can’t provide the date in the foundation data, please discuss with the onboarding team.

    MAAS readiness:

    A survey has been completed by the funds. A CRT Alert will be sent out later this week summarising and includes reporting links.

    Internal readiness is on track. Weekly updates provided to industry through the CRT Alerts.

    We are continuing to push for the online portal solution which will also allow for any policy/law changes that have low volumes but timeframes are not clear yet.

    Discussion

    Funds want to know what will be displayed online and if they will be asked for comment.

    We will be consulting with funds and we want to understand what individuals want to see? What do they want to see from their fund?

    Action item:

    • How regularly can you lodge after July 2018 – question to Ty Winmill from Sam Finucan.
    • TFN matching – do funds update with TFN if matched or open/closed?

    10. Other Business

    Presented by Shaun Ferabend and Robert Drummond

    10.1 Industry questions for the ATO

    Discussion on Lost Member Reporting post MATS. Prior to October 2018 refresh data with foundation data and then report in data standards.

    Release authority - consolidation of Release authorities – still scheduled for November 2019.

    Lost Member register question about whether it will continue; however there will be no need to when going into MATS and MAAS.

    10.2 When is the ATO looking at decommissioning ECI?

    ECI decommissioning – fund question about when it will be decommissioned?

    Funds which are not in Superstream will still use ECI and non Superstream remittances such as USM recovery use ECI. Therefore, ECI will continue until further notice.

    Most of the channel is surcharge and RARN and decommissioning is not on the radar yet.

    Agenda Item

    Action required

    Who

    What

    When

    3.0

    Clarify how BDE will deliver the alert/letter

    John George

     

    Response contained in minutes

    3.0

    Present at next SASG in June an overview of the process

    John George

     

     

    3.0

    Provide a copy of the member version of the approval letter with contact details provided

    John George

     

     

    4.2

    Provide electronic copy of handouts to SASG members ASAP

    John George

     

    DHS enclosure contained in minutes

    4.2

    Provide clarification to funds on the channel eg portal - When do funds have to report? How will they report?

    Julie Rowland

     

    Response contained in minutes

    6.0

    SuperNews, add to minutes how to subscribe and attach the flyer.

    Kylie Smith

     

     

    6.0

    Timing of the combined monthly SuperNews is the 1st or 2nd Thursday of the month –

    Kylie Smith

     

    Completed

    9.0

    Provide details on how regularly can funds / providers lodge after July 18?

    Ty Winmill

     

     

    9.0

    TFN matching – Confirm the best action - If a TFN is changed after matching is it an update or closed or open?

    Tracie Crowden

     

     

    Meeting closed 2.10pm.

      Last modified: 22 Jun 2018QC 56068