Unclaimed money, lost member and inactive low-balance account reporting obligations webinar
Questions and answers
This document provides answers to the following common questions which were asked during the August 2019 Unclaimed money, lost member and inactive low-balance account reporting obligations webinar.
What is considered as reasonable efforts to contact the member?
While reasonable efforts is not defined in the law, we have provided guidance in the Unclaimed superannuation money protocol document available on our website. Some examples include phoning the member using the last known phone number, writing or emailing the member requesting further information.
How to report a member who meets the definition of more than one type of USM?
Where the member meets the definition of more than one type of USM the order of precedence is outlined in legislation as follows:
- non-member spouse or a deceased member
- member who is a former temporary resident identified on a section 20C notice
- member who has reached eligibility age
- small or insoluble lost member accounts
- inactive low-balance accounts.
What is the unclaimed superannuation money date?
This is the date your member‘s status is assessed. It is either 30 June or 31 December. Please ensure this date is completed correctly on your USM statement.
When will the new reporting code for inactive low balance accounts be available?
The new reporting code ‘L’ will be included in the Rollover MIG V3.0 which will be available from April 2021.
For inactive low balance accounts, if a member meets all conditions for ILBA but still has a binding beneficiary nomination in effect (for example if the nomination was made 2 years ago and the nomination still has 1 year to run) must the benefit still be paid to the ATO?
Sub-paragraph 20QA(1A)(b)(iii) when read with the introduction in 20QA(1A)(b) is clear that the period of validity of a binding beneficiary nomination is not a relevant consideration, rather the relevant consideration is what the member has done in relation to the binding beneficiary nomination (ie have they made or amended it) in the last 16 months.
When will ATO be sending USM out message and payment to Funds?
The ATO currently sends out USM messages and payments to funds when the member elects a rollover. Proactive consolidation is expected to commence in October 2019.
How do we treat accounts that are no longer unclaimed, lost or inactive?
Funds will be unable to submit this reporting to us via SuperStream because the system does not accommodate reporting that contains a message without an associated payment.
While there is a legislative requirement in respect of the reporting of these accounts, we recognise that broadly this information is provided to us through other channels; particularly events based reporting under MAAS and MATS. Taking this into consideration and the low risk associated with this particular reporting requirement the ATO, will not apply compliance resources to require the reporting of these accounts on a USM statement.
This document provides a copy of the Unclaimed money, lost member and inactive low-balance account reporting obligations webinar held August 2019 and answers to some common questions.