“Advisers need to get their clients to make sure they are using SuperStream or it’s going to be a breach of reg 6.17,” she said.

“APRA funds that are constitutionally protected funds don't have to meet SuperStream requirements, so if an SMSF is rolling over to one of these types of APRA funds, it's going to be a breach of reg 6.17 even though it's no fault of the trustees.

“The reason for that is that the transfer won't be made through SuperStream. It's going to happen by bank cheque or bank transfer.”

Banton said another issue that is of concern is when a member is rolling their balance in an SMSF over to a new SMSF, which is a related-party fund.

“Of course, [the question is] why would the super trustee use SuperStream when they can just do a quick bank transfer, which is a lot easier? But once again, unfortunately, it's a breach, and it will be reported to the ATO because we have no discretion about that,” she said.

Banton added that although the ATO is not currently undertaking compliance action regarding these kinds of SuperStream breaches, she warned that the situation could change quickly so trustees should be educated and adopt “good SuperStream habits”.

Bank details are also important to consider when using SuperStream as the SMSF bank account registered with the ATO is the one that can't be used by trustees for any other purposes.

“However, if the trustee then nominates a different bank account that's not registered with the ATO in terms of getting a transfer through, it's going to delay that transfer, and it may affect other things, like winding up a super fund at the end of the day,” Banton said.

“There are also plenty of other hold-ups that stop SuperStream from working. One is using an incorrect PRN, payment reference number, and it’s imperative that the PRN matches the amount being transferred otherwise it’s going to cause delays and a potential breach.”

She said another issue that can delay or complicate any transfers through SuperStream is the inability to have just one set of procedures.

“I understand that this can be frustrating, but you're not going to be able to have one set of procedures to roll money out of an SMSF to all APRA funds and the reason for that is that they've all got a different set of requirements,” Banton said.

“It can take time to work out what those requirements are, especially when some are requesting bank statements that have been certified and others are requesting certified trust deeds to be sent in,” she added.

“To be fair to the APRA funds, we have seen an increase in documentation requests under the Know Your Client requirements and it is also because of the increased number of data breach scams we continue to see.”