While the ATO statistics helped dispel some inaccuracies regarding operating expenses for SMSFs, it also provided some important data in relation to tax agents and the number of SMSFs they service.

“The statistics show that the average number of SMSF clients was 34 and the median was 10. However, when you take a closer look at the data, it tells a much more compelling story,” Mr Dunn said.

“[The statistics indicate that] 50 per cent of all tax agents in the SMSF sector do less than 4.5 per cent of total SMSFs, an average of 3.7 funds per agent.”

This in contrast to the remaining 50 per cent of tax agents, he said, that have an approximate average of 82 funds under their tax agent’s licence.

“If you break this down at less than 20 funds, it represents 64 per cent of agents (average less than six funds), with the remaining 36 per cent having an average of 109 funds,” he stated.

“To me, this highlights some important points and challenges for the regulator. The numbers of agents are marginally declining; however, that ‘gap’ between the providers is going to create continuing problems as technology evolves, further legislative change and regulatory reform.”

It is these types of risks, he said, that need to be further addressed as part of the future advice framework for the SMSF sector.

Mr Dunn previously predicted there would be a reduction in service providers in the medium to long term in his Future of SMSF Report.

In his report, Mr Dunn stated that the removal of the accountant’s exemption from 1 July 2016 had clearly had a detrimental impact on the growth of the SMSF sector.

“Such measures have failed on the government’s objective to improve access to advice — advice that historically has included trustees seeking the services of accountants to assist them with their SMSF, whether compliance or advice related,” he said.

While Mr Dunn said he was not advocating for the return of the accountant’s exemption, the policy settings around how SMSFs fit into the financial product framework needed to be re-examined.

He also stated in the report that tax agents servicing small numbers of SMSFs would have some significant challenges ahead.

“Put aside the need to upskill in terms of knowledge as a result of the super reforms, we also know that this group has a very high proportion of unlicensed practitioners, with 57 per cent also still delivering services annually or re-actively,” the 2018 report said.