Superannuation Alert - 11.09.13

Financial Services eBulletin - 11 September 2013


The Lander & Rogers Superannuation Alert is a brief overview of new developments in the superannuation industry and is in addition to our Superannuation Update, which analyses the main developments of interest in more detail.

    • SuperStream FAQs:

- FAQ 6: Does the provision of gateway services constitute a material business activity for RSE licensees and so become subject to the requirements of Prudential Standard SPS 231 Outsourcing?

- FAQ 7: What approach should an RSE licensee adopt if it considers that a fund under its trusteeship, or a Division within a fund, is at risk of not being ready to meet its published transition-in completion date for the purposes of the Superannuation Data and Payment Standard?

  • Reporting framework FAQs:

- FAQ 45: SRF 330.0 requires an RSE licensee to report information about expenses associated with insurance administration for an RSE. What information should an RSE licensee seek from their insurer to complete this item?

- FAQ 46: If an RSE licensee implements a currency hedging program at an investment option level, rather than at the level of asset classes within an investment option, can the same currency hedging ratio be applied across all international asset classes within that investment option?

  • On 2 September 2013, APRA released the final version of its Prudential Practice Guide CPG 235 - Managing Data Risk for all APRA regulated institutions, including the superannuation industry. This PPG 'aims to assist regulated entities in managing data risk. It is designed to provide guidance to senior management, risk management and technical specialists (both management and operational).'
    • In the Response to Submissions, APRA responded to, 'the main issues raised in submissions on SRS 700.0 [Product Dashboard], SRS 702.0 [Investment Performance] and SRS 703.0 [Fees Disclosed].' APRA outlined that the, 'two major themes expressed in the submissions concerned lodgement timeframes and uncertainty about what information will appear in APRA’s statistical publications.' In response, APRA stated that:

- It 'is not altering lodgement timeframes but is maintaining its existing process for entities seeking adjustment to the lodgement timeframes for a particular form. Where an entity considers that it cannot meet the lodgement timeframe it should contact APRA Statistics; and

- 'With regards to APRA’s statistical publications, APRA will consult in the near future on the publication of the information reported to it under the new reporting requirements. Industry stakeholders will have an opportunity to comment on the contents of the publications at that stage.'

  • APRA also outlined that 'APRA will determine final versions of SRS 700.0, SRS 702.0 and SRS 703.0 … before the end of September 2013. SRS 702.0 commences on 30 September 2013, with the first data due to be submitted by 28 October 2013. SRS 700.0 and SRS 703.0 commence on 31 December 2013 with the first data due to be submitted by 28 January 2014.'


  • Other noteworthy decisions include:

- a change to the reporting requirement in relation to insurance premiums on SRF 703.0 to, 'better reflect the features in insurance arrangements that may lead to variation insurance premiums'; and

- APRA's decision to 'initially apply SRF 702.0 to MySuper products only, and consult further with industry regarding appropriate investment performance reporting for select investment options.'

  • On 2 September 2013, the ATO updated its website and published information about auditor contravention report instructions. The ATO outlined that the '2013 version of the Auditor contravention report (ACR) instructions, Completing the author/actuary contravention report (NAT 11299), gives approved self-managed super fund (SMSF) auditors and actuaries information about reporting criteria and examples to help complete the Auditor/actuary contravention report (NAT 11239).'

 The ATO notes that the key changes in the 2013 version are 'the inclusion of:

  • R4.09A Operating standard - money and other assets to be kept separate: See Table 1: List of reportable sections and regulations; and
  • an additional example to 'Test 6: Financial threshold test'. The example has been added to further clarify the reporting of contraventions over 5% of the value of the fund's total assets.'


Further information

All information on this site is of a general nature only and is not intended to be relied upon as, nor to be a substitute for, specific legal professional advice. No responsibility for the loss occasioned to any person acting on or refraining from action as a result of any material published can be accepted.