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  • CRT Alert 072/2018

    9 October 2018

    Legal obligations and your transition to MAAS

    Funds transitioning to the Member Account Attribute Service (MAAS) have requested more certainty and clarity around certain legal obligations during their transition.

    Funds are required to report Foundation Data to us via MAAS as part of their transition. Given the size of change we recognise that it may take some time to receive and process this initial data load (in both fund and ATO systems), depending on the size of the fund. This may therefore impact a fund's ability to meet some legislated timeframes.

    The following outlines two legislative requirements that may be impacted during your transition to MAAS and our compliance approach in relation to them.

    1: Tax file number (TFN) validation

    You are required to obtain a TFN validation notice from us within three business days of receiving:

    • a rollover or transfer request
    • an initial employee registration request.

    The relevant legislation is the Superannuation Industry (Supervision) Act 1999 (SISA) and the Superannuation Industry (Supervision) Regulations 1999 (SISR).

    The above requirements relate to section 299TD of SISA, regulation 6.33D of SISR and regulation 7.07B of SISR respectively.

    You can meet your requirements via SuperTICK, or MAAS in some circumstances. The MAAS responses that equate to a section 299TD notice are outlined in the MAAS Business Implementation Guide.

    2: Reporting new accounts

    You are required to report the opening of a new account within five business days via MAAS.

    This is a requirement under the MAAS legislative instrument - Taxation Administration Member Account Attribute Service – the Reporting of Information relating to Superannuation Account Phases and Attributes 2018.

    Our compliance approach

    We understand that as you transition to MAAS you may encounter issues relating to your implementation that may take time to work through. We also understand that these issues may impact your ability to comply with the above obligations.

    We will be taking a pragmatic administrative approach to compliance and advise that we will not be taking action against funds during their transitional period.

    For funds preferring to resolve any Foundation Data or transitional issues prior to commencing their 'live' reporting - we confirm that we are comfortable with this approach.

    We have consulted with the Australian Prudential Regulation Authority (APRA) who support the ATO’s transitional implementation approach.

    See also:

      Last modified: 10 Oct 2018QC 56975