The superannuation data and payment standards stipulate that a trustee must roll over transfer an amount under sub-regulation 6.34(2) no later than three business days after they receive the request.

Ms Banton told SMSF Adviser that auditors will be looking for the appropriate documentation, which specifies which particular party has initiated the super fund rollover.

“Is it coming from the member or the trustee? There’s a difference between the member initiating the rollover or a transfer from a super fund, and when the trustee is finally made aware of that as well,” she said.

“We’ve got two different strands that we need to take into consideration because it’s not until the trustee becomes aware or is notified of the transfer or rollover that the clock starts ticking on that ‘no later than three business days’ timeframes.”

Ms Banton spoke to SMSF Adviser ahead of the SMSF Adviser Technical Strategy Day 2022 in October, where she will participate in a panel session aimed at providing a troubleshooting guide to SuperStream rollover issues.

Moderated by Smarter SMSF CEO Aaron Dunn, the panel will unpack the common SuperStream issues facing advisers (including system issues arising with rollovers to and from APRA-regulated funds), and how auditors are approaching rollovers in their audits, and what the ATO’s current stance is.

Industry in state of flux

Advisers will need to ensure that trustees can provide auditors with a series of minutes that stipulate the timeframe, dates, and mechanisms of how those transfers and rollovers occurred, but Ms Banton flagged that the industry will continue to be in a state of flux until the ongoing teething issues surrounding SuperStream are ironed out.

“As auditors we are still waiting to see what we’re going to get from clients. They’re still using their administration software to be able to help them put these SuperStream processes into effect,” Ms Banton said.

“So, we’re going to see issues popping up until we get to the point where we have passed those teething problems, the processes have been smoothed out, and everybody understands how it works, and we start seeing these processes occurring within the required timeframe.

“SuperStream isn’t there yet, and we’re all learning about this as we go. Unfortunately, it’s always the case when you have an undertaking as massive as SuperStream.”

Things to cover off

For advisers navigating SuperStream rollover issues for their clients should run through a checklist to ensure they have covered all of their bases, Ms Banton suggested.

This includes verifying all SMSF details in the ATO database, and ensuring that the fund has a bank account specifically for use only by the super fund.

Furthermore, advisers must ensure that an electronic service address (ESA) that does both rollovers and contributions is in place because not all ESAs offer both facilities.

Alongside this, advisers must ensure that the client’s ABN is active, Ms Banton pointed out.

“For funds that are winding up, the ATO has extended that timeframe to cancel the ABN from three days to two weeks to facilitate rollovers,” she said.

“But where the fund has wound up and the ABN has been cancelled two weeks after but money is coming into the fund afterwards, you are going to have issues there. Those sorts of problems have not yet been resolved through the ATO, nor has SuperStream resolved them yet.”

Other issues that could hinder the process include entering the incorrect tax file number, or proof of identity issues where a client’s name does not match the details of their tax return from the previous year because they might have changed their name, Ms Banton said.

To hear more from Shelley Banton about how auditors are approaching SuperStream rollovers in their audits and how you can navigate the process, come along to the SMSF Adviser Technical Strategy Day 2022.

It will be held on Thursday 6 October at Crown Towers in Melbourne, Friday 14 October at the Four Seasons Hotel in Sydney, and Wednesday 26 October at the Brisbane Convention and Exhibition Centre.

Click here to buy tickets to the conference and secure your spot today!

For more information about the conference, including agenda and speakers, click here.