Justin Micale, Assistant Commissioner, Self Managed Super Funds Risk and Strategy
Speech delivered at the CA ANZ National SMSF & Financial Advice Conference on 20 October 2022
Check against delivery
Thank you and good morning everyone. I hope you are enjoying the conference so far.
It is great to finally be attending this event in person and providing you with insights into what we’re seeing in the SMSF sector.
Today, I will talk to you about our responsibilities as the regulator and the important role you play in helping maintain the integrity of the sector.
I’ll cover what we’re finding from some new demographic analysis we’re undertaking, and how this will drive our strategies going forward. This research will also help identify where we need to do more to help trustees get it right.
What the data tells us
I know I don’t have to remind you that self-managed super funds are an integral part of Australia’s super system holding just over a quarter of the $3.4 trillion in the Australian superannuation asset pool.
Our recently released statistical report shows there are just over 603,000 SMSFs, with over 1.1 million members holding an estimated total asset value of just over $868 billion.
The data we regularly publish provides information about the health of the sector, including demographics, costs and asset allocations. They are primarily based on SMSF annual returns, new registration data and auditor contravention reports lodged with us.
The data provides useful trends and information about the performance of the entire sector. This can help inform prospective trustees and assists policy makers and other stakeholders to make decisions that impact the sector.
It’s important to understand that our statistics are based on annual return information from all lodging funds regardless of their size or asset mix.
The investment performance data shouldn’t be used for comparative purposes other than annual comparisons of the SMSF sector as a whole.
Apart from these statistics, we’re undertaking demographic analysis to understand how many fund members have links to small businesses and private wealth groups, to see if they display different behaviours.
The research has only just commenced but it is already providing some useful insights to help us build a deeper and more differentiated understanding of the population.
For instance, our preliminary results show around 45% of funds have links to a small business while 25% are linked to a private wealth group.
We have also found that as a proportion, the incidence of non-lodgment and loans to related parties is higher for those funds with members operating a small business than those linked to other segments.
Our role as regulator
The ATO’s role as the regulator of SMSFs is focussed on protecting the integrity of the system by ensuring funds pay the correct amount of tax and operate within the law for the sole purpose of providing retirement benefits to their members.
This role is shaped by the policy framework which as you know is one where members of the fund are also its trustees and as such are in a unique position to protect their own interests.
They have direct access to their retirement savings, have greater flexibility and choice in investments, and are personally responsible for the actions of the fund.
While our role does not extend to determining whether an individual should or shouldn’t set up an SMSF or whether it is making the right investment choices, we do want to ensure they go into this system with their eyes wide open.
To achieve this, we provide prospective and current trustees with access to information to enable them to make an informed decision about whether an SMSF is the best retirement savings vehicle for them.
This includes making our annual statistics publicly available and providing them with information to help them understand their responsibilities, so they enter and remain in the system for the right reasons and can effectively self- manage their fund.
The approach we take to managing risk in the sector is multi-faceted and has a strong preventative focus. The compliance element of our strategy is informed by our assessment of those behaviours which put the system most at risk rather than being about addressing every breach. I will elaborate on those areas shortly.
As the regulator, we do not have a prudential role and are not responsible for developing the law, providing financial advice, compensating victims of scams or resolving disputes between trustees.
In late 2020 we commissioned an independent research study to keep our understanding of the sector, and the support trustees need up to date.
We know from both our research and independent studies that there are distinct clusters of SMSF trustees reflecting a wide variation in their knowledge, confidence, and engagement.
Clusters vary from one extreme to the other. There are those who are very confident and financially savvy, have an interest in investing and finance, and attend seminars to improve their knowledge. These individuals have a high level of financial literacy and fraud awareness.
Then at the other extreme we have the unprepared trustees who lack the financial confidence and capability to manage their SMSF. They tend to be impulsive and ad hoc in their decision making, are price sensitive and reluctant to invest in professional advice. These individuals have low financial literacy and fraud awareness. One third of this group regret their decision to start an SMSF.
In-between these extremes are trusting delegators who seek professional advice but often leave decisions to someone else without doing any research themselves.
It is vital for trustees to understand the importance of the ‘self’ element of self-managed funds. Professional support and advice is important but trustees need to understand they are ultimately responsible for running their super fund. We are all aware of examples where trustees have put their total reliance on the wrong person and have been caught out by a scam.
While the majority of trustees managing their SMSF are doing the right thing and are building their retirement savings, for those who do not have the benefit of sound advice, this often results in non-compliance and puts their retirement savings at risk.
Unfortunately for you this can also mean they’re a more challenging client to support. It’s clearly in the best interest of both the ATO as regulator and industry professionals to address this.
For the ATO, we’re developing a series of guides to support trustees throughout the lifecycle of their SMSF. For prospective and new trustees there’s our publication entitled "Starting an SMSF", which provides information on what’s required to set up an SMSF.
Then for anyone who needs to know about what’s involved in ceasing their SMSF we have released our "Winding up an SMSF" publication. We are currently developing a "Running an SMSF" publication which will be the last one in this series.
We also have a range of other support products on our website such as videos, checklists, case studies and webinars, so I would like to encourage you to share these with your clients as it can complement the support you provide.
So what gets our attention?
Pleasingly, the overall tax and regulatory performance of the sector continues to remain strong.
However, as we are seeing indicators of heightened risk in the sector, we are scaling up our compliance activities.
These activities have a particular focus on behaviours that put retirement savings at risk or inappropriately take advantage of the concessional tax environment.
For the next part of the presentation, I will take you through those areas of most concern and give you an insight into how we are addressing these risks.
ID fraud and investment scams
Let’s start with fraud as it’s the one on everyone’s lips at the moment, and the consequences for those impacted can be devastating.
Fraud in the SMSF system can result in a person’s retirement savings being stolen and lost forever which is why this is an area we pay very close attention to.
From the outset, I would like to reassure you that the recent Optus data breach does not provide fraudsters with direct access to tax or super records, but it does mean we all need to be extra vigilant.
We are working across government agencies to identify and mitigate risks and have put safeguards in place to protect those impacted.
For instance, APRA has also encouraged the funds it regulates to undertake additional proof of identity checks prior to rolling money over into an SMSF. This additional control may delay the processing of these requests.
That said, while ID fraud and investment scams are still rare in the SMSF sector, they are becoming more prevalent.
In the 2022 financial year, we identified increasing numbers of individuals that were victims of identity fraud where SMSFs were registered without their knowledge or consent. Luckily, for most victims we detected the fraud early so we could protect their super, but not for all.
The other key type of fraud arises where scammers contact individuals and coerce them into providing personal information, setting up an SMSF and/or investing in their bogus products. You may have seen ASIC alerts and recent media discussing investment scams.
These scammers are becoming increasingly sophisticated impersonating well-known Australian companies and using personal details to gain trust.
They use various methods to contact people such as email or cold calling, pretending to be financial advisers and encouraging them to transfer their superannuation into a new SMSF or investment product. The investor is often promised high returns.
Once they have their personal information, they seek to use it to establish an SMSF, rollover money into the fund and steal their retirement savings.
This reinforces the need for individuals, and you as their advisers, to treat contact from any third parties in relation to their investment and superannuation choices with caution.
It is important to remind your clients to check they’re dealing with a licenced financial adviser. They can check this on Moneysmart’s Financial Adviser Register. I suppose it comes back to the old saying, if it sounds too good to be true it probably is!
A key strategy we have deployed to address fraud and scams is to issue Alerts. When a new SMSF is set up, or a member is added to an existing SMSF, the ATO sends an alert via a text message or email.
We also send an alert when the SMSF’s bank account, electronic service address or authorised contacts for the fund are changed.
If your clients receive an ATO SMSF alert and are not aware of any activity, make sure they act quickly and contact us, so we can stop the fund registration or the change of details from proceeding.
This is why it’s vital you ensure your clients’ individual contact details such as their mobile number and email address are kept up to date with us, as this will ensure they receive our alerts and are notified of any changes to their SMSF.
Finally, if you’re asked to register an SMSF for a new client make sure you verify their identity as we have seen some tax agents unwittingly caught up in registering fraudulent funds.
Strong client verification helps to protect tax practitioners and their clients from identity fraud.
Illegal early access
Early access is the most common risk in the sector.
It occurs when individuals access their retirement savings before meeting a condition of release. Not only is this illegal, but money taken out of superannuation early has a detrimental impact on an individual’s retirement nest egg.
As you know, there are only a limited circumstances where a member can legally withdraw their super, such as where a member reaches their preservation age and retires, is 65 years old (even if not retired) or has died.
Unfortunately, we are seeing an increasing number of trustees taking advantage of their direct access to their superannuation bank account and they are using these savings to pay for items such as business debts, holidays, renovations and new cars.
We see illegal early access play out in two main ways.
Firstly, new registrants enter the system purely for the purpose of getting access to their super.
This is often with the support of promoters who, in return for a high fee, help these individuals establish an SMSF and withdraw their super before they are legally entitled to.
Once the money is rolled over from their APRA fund and then withdrawn from the SMSF bank account, these members abandon the fund and never lodge a return.
This behaviour appears to be on the rise as there has been a significant growth in SMSFs failing to lodge their first ever annual return. In 2020-21 over 20% or 5,600 of the 28,000 new registrants have not lodged.
Secondly, we also know that existing trustees sometimes access their super early. In some instances, they will stop lodging to avoid detection or to get additional time to put the money back in before they lodge.
If they do lodge, regardless of whether the money was put back into the fund, early access is usually picked up and reported to us in an auditor contravention report as a loan or breach of the payment standards.
To address the increase in illegal early access we have a strong focus on warning people not to be tempted to go down this path and for those that don’t heed our warnings ensuring there are consequences for their actions.
We have an extensive communication campaign in place and as part of our new registrant program we risk assess every individual entering the system and scrutinise those that may be registering for the wrong reasons.
In the 2022 financial year, this program has protected over $170 million in retirement savings from leaving the super system illegally.
This year we are scaling up our compliance actions, so you will see an increase in trustees being disqualified for illegally accessing their super, and in the number of amendments being made to assess amounts withdrawn in the members personal tax returns. Penalties and interest charges can also apply.
We are also stepping up our focus on licenced and unlicenced promoters of illegal early access schemes. This behaviour is unacceptable particularly as we know promoters often target people who are in vulnerable communities, under financial pressure and with low financial and super literacy.
Our scrutiny of those engaging in promoter behaviours is intensive and may involve a number of law enforcement agencies. The sanctions can include loss of professional licences, significant penalties, and criminal prosecution.
As an example, the ATO took legal action against a promoter who set up over 30 SMSFs and illegally accessed their super. The Federal Court imposed a $220,000 penalty and a seven–year ban.
Non-lodgment of SMSF annual returns
Another key regulatory risk we’re focused on is non-lodgment.
The lodgment of an SMSF annual return is a fundamental obligation for all trustees including those in retirement phase.
The SMSF annual return provides us with visibility of the fund’s compliance with its regulatory and tax obligations, and the super balances of its members. The failure to meet this obligation can also be an indicator of broader compliance issues including illegal early access.
To give you an insight into what we’re seeing, there are around 24,000 funds who haven’t lodged their first return and a further 80,000 lapsed lodgers with one or more outstanding returns.
For the 2020-21 year specifically, there are around 67,000 returns outstanding so while I know it has been a challenging year these figures highlight there is a lot of ground to make up.
The number of funds that fail to lodge their first annual return has also grown significantly from 7% in the 2016 financial year to over 20% in the 2021 financial year.
We call this population ‘never’ lodgers. This is particularly concerning because this is not a good start to their journey as a trustee. As previously mentioned, if we see there has been a rollover into these SMSFs, this is a strong indicator that illegal early release may have occurred.
We refer to our other non-lodger population as 'lapse' lodgers.
Where previously compliant funds stop lodging, we know this may be due to trustees experiencing personal difficulties but can also be an indicator of broader regulatory issues. We have found when an SMSF has an unrectified contravention, it can be a precursor to failing to meet their lodgment obligations.
Lodgment is vital to ensure the fund retains its complying status on SuperFund LookUp as funds who have overdue returns by more than 2 weeks may have their regulation details removed. This restricts the SMSF from receiving rollovers and employer contributions.
To take you back to the research findings, it is critical for trustees to develop good compliance habits in the early stages of setting up an SMSF.
Helping your clients meet the fundamental requirement to lodge their annual return on time, is the first step in ensuring they understand and comply with their obligations.
So how are we tackling this?
As a first step to encourage compliance, we remind trustees of their lodgment requirements via articles and targeted mail outs. And whilst this does deliver positive results for the majority of trustees, there is a persistent group who continue to ignore our reminders.
A key strategy we deploy for this group is our 3 Strikes letter campaign.
I have spoken about this process before so won’t go over it in detail again, but to provide an update, we have just disqualified 104 trustees who failed to respond to our first batch letters.
We also have a specific focus on tax agents and auditors who have their own personal SMSF lodgment obligations outstanding.
I realise it is a busy industry, but we do hold professionals to a higher standard when it comes to meeting their tax and regulatory obligations.
We have issued red warning letters to this group and will be taking action on those who have failed to respond soon.
If you have received one of these letters you should take it seriously and act now because if you are disqualified it may have an impact on your professional reputation and registration.
As always, if you or your clients are experiencing difficulties, we encourage you to contact us so we can help. Coming to us first is always a better option than waiting for us to come to you.
Regulatory contraventions
Now I’ve already mentioned contraventions a couple of times today so I want to reassure you that overall the sector displays positive regulatory compliance, with around 97% of the lodging SMSF population having no reportable contraventions from their independent audit.
Whilst this is encouraging, in the 2022 financial year, we’ve received ACRs for 13,558 funds with 39,997 contraventions being reported. This is an increase of nearly 3.5% in the number of SMSFs with ACRs lodged and an increase of nearly 6.3% in the number of contraventions reported compared to the 2021 financial year.
The reason for this growth is not clear but increased levels of SMSF auditor independence stemming from the revised code is likely to have contributed to enhanced reporting which I think is a positive outcome for the integrity of the sector.
The most common contravention relates to members having accessed their retirement savings early which is often reported as a loan to member or a payment standards breach. As I’ve already said, accessing the assets of the SMSF for any use where a condition of release hasn’t been met, even if it’s to support a member’s business, constitutes early access.
We find the main drivers of regulatory contraventions are financial stress, poor record keeping and a lack of understanding of the rules.
How we respond to breaches depends on a number of factors such as the impact of the breach on the fund, the compliance history of the trustee and their attitude to meeting future regulatory obligations. As you would expect, we treat a simple mistake very differently from someone who shows a blatant disregard of the law.
For more serious contraventions, there are a range of sanctions that we may apply. For instance, in 2021–22 we disqualified 252 trustees for serious breaches of the law, while other contraventions attracted administrative penalties of around $3.4 million.
These consequences can have wide ranging impacts as the disqualifications are published and trustees are personally liable for penalties imposed.
We also monitor SMSFs with large asset balances and high rates of growth, and investigate situations where individuals seek to inappropriately access concessional tax rates for superannuation via the use of an SMSF.
The most common issues we identify involve situations where group structures have been utilised to channel income or assets to an SMSF in a way that seeks to circumvent contributions caps and other tax and regulatory rules.
We have dealt with cases involving the under-valuation of assets acquired from related parties, and income from property developments, private company dividends, unit trust distributions and personal services income being inappropriately diverted into the SMSF.
So what should your clients do if they go off track?
As I said earlier, ultimately our role as regulator is to protect the integrity of the SMSF sector.
If you identify issues with your client’s affairs it’s important for you to work with them to develop a rectification plan to help them get back on track.
Where there is a serious regulatory contravention that may not be able to be rectified, it is important you bring it to our attention via our voluntary disclosure service as soon as possible.
We will then work with your client to find an appropriate resolution which may include removing them from the sector altogether. Where a client is forthcoming and works with us during the voluntary disclosure, we will also look to minimise penalties as appropriate.
Further information about our voluntary disclosure service is available on our website.
Approved SMSF auditors – adequacy and independence
The next risks I want to talk to you about relate to SMSF auditors.
The SMSF annual audit is founded on the process being independent and adequate. SMSF auditors provide a critical service in ensuring the validity and accuracy of an SMSFs financial statements and its compliance with super laws.
I am pleased to say we continue to see the vast majority of auditors demonstrating a high level of competency and professionalism.
In the last year, since our approach to managing compliance with the changes to the independence standards came into play, we have seen 31% of funds engage the services of a new auditor.
This is above the 20% churn we usually see from year to year and appears to have had a positive impact on the audit process as there has been an increase in the level of reporting.
I view this as a positive shift for the sector as the majority of these contraventions are not serious and can easily be rectified before potentially creating bigger issues down the track.
This year our compliance program for SMSF auditors will continue to use data and intelligence to risk assess and deal with higher risk firms, focusing on behaviours such as audit adequacy, in-house audits and reciprocal auditing arrangements.
In collaboration with ASIC we are reshaping our approach to become more real time and differentiated, meaning we are looking to increase our coverage and introduce a broader range of treatments to address risks within the industry.
This program of work is expected to deliver a higher rate of referral to ASIC in the coming financial year and, as a result, increased visibility on how both agencies are working effectively as co-regulators to address inappropriate auditor behaviours.
An important example of this joint work was highlighted in an ASIC media release where they announced the outcome of 18 ATO referrals involving auditors who contravened the independence requirements.
These auditors were all involved in reciprocal audit arrangements where they audited each other’s personal SMSFs. ASIC accepted voluntary cancellations or imposed conditions on the registration of these auditors because of the independence threats.
In other recent reviews we’ve conducted, which resulted in referrals to ASIC, we’ve identified some common issues. These include failing to obtain sufficient appropriate audit evidence, inadequate evaluation of the audit evidence; and inappropriate documentation to support the conclusions reached.
Documentation of an SMSF audit is necessary to determine that the audit has been properly conducted. This is the case even if there were no contraventions.
SMSF auditor number misuse
Another focus area for our program is identifying SMSF auditor number misuse which we refer to as SAN misuse. SAN misuse occurs where an approved SMSF auditor’s details have been incorrectly reported on an SMSF’s annual return.
In the last 3 years we have invested in identifying instances of SMSF annual returns being lodged where an auditor’s details have been entered incorrectly or an audit has not been undertaken. This work relies heavily on auditors responding to our mailouts containing lists of funds which have quoted their auditor number.
As a consequence of this partnership, we have noticed a significant positive shift in the way SANs are being reported by tax agents and trustees on their annual returns.
This has been supported by action taken by the TPB following ATO referrals. Recently the TPB determined that the 2 agents acted dishonestly and without integrity in their dealings with the ATO, by making false statements about the completion of audits.
The TPB terminated the registration of these agents as they were found to no longer meet the tax practitioner registration requirement of being a fit and proper person after lodging SMSF annual returns with details of audits that had not been done.
In one of the cases the tax agent lodged over 90 tax returns with false auditor details. The auditor advised us they had not audited the funds. The tax agent was found to have misled clients by advising them their SMSFs had been audited and charging for this service even though they had not been completed.
We will continue to work with auditors to identify instances where SAN misuse may have deliberately occurred. Where appropriate, referrals will be made to the TPB for further action to be considered.
This month we have sent client lists for the 2021–22 financial year to all auditors so they can review all the annual returns that have been lodged where their SAN has been quoted.
For the final part of my presentation, I will focus on a number of key changes relevant to the sector and the support and guidance we provide to help you navigate this.
Support and guidance – NALE
So let’s start with non-arm’s length expenditure or NALE as we like to call it, as it has clearly been a hot topic for the profession over the last few years.
Before I dive into this, please note my comments only focus on SMSFs. We know there are differences in how an SMSF operates compared to APRA regulated super funds, but given the focus of the session, I will steer away from that today.
As you all know, back in July 2021, following consultation with professional and industry associations, we released Law Companion Ruling LCR 2021/2 to clarify our interpretation of the non-arm’s length expenditure legislation.
This ruling is underpinned by a widely accepted principle which is: trustees must enter into all transactions on an arm’s length basis to maintain access to concessional rates of tax.
It also makes it clear that the NALE provisions will not apply where a trustee, acting in a trustee capacity, performs a service such as bookkeeping for no remuneration. However, services provided to the SMSF in a professional capacity, such as where a partner uses their firm to prepare the financial accounts for their SMSF, must be charged for on an arm’s length basis. It is acceptable for discounted prices to be charged providing they are consistent with normal commercial practices.
The ruling also stated that in some instances, non–arm’s length expenditure of a general nature such as administrative costs to manage the fund, will have sufficient nexus to all of the income derived by the fund for a particular year.
This has clearly been the most contentious item in the ruling, and we are well aware of the significant tax impact which may arise even where the relevant expense is immaterial.
In recognition of this, we extended Practical Compliance Guideline PCG 2020/5 for a further year, to provide trustees with additional time to transition their arrangements.
This was particularly important given the change in Government and the previous Government’s announcement of its intention to undertake further consultation regarding this legislation.
In practical terms, the extended PCG means that while the law has not changed, we will not apply compliance resources for the 2018–19 to 2022–23 financial years to consider whether the non-arm’s length expenditure provisions apply to general expenses incurred on or before 30 June 2023.
It is important to recognise this compliance approach doesn’t have broader application. We will continue to take compliance action for higher risk transactions involving non-arm’s length expenses relating to specific items such as acquisition of an income producing property.
Trustees should pay particular attention to transactions involving related parties and be able to demonstrate that they have been undertaken on an arm’s length basis.
I also want to take this opportunity to thank the professional associations such as CAANZ for making representations about areas where further clarity is required.
This resulted in us extending our compliance approach for non-arm’s length limited recourse borrowing arrangements in PCG 2016/5 and has helped inform our advice to Treasury on potential policy considerations.
We will also look to provide further guidance on issues which are material and have industry wide application to ensure SMSFs have greater levels of certainty on how to apply the rules. However, I do want to make it clear that it is not possible to provide advice on every hypothetical scenario because this will ultimately come down to the facts of the situation.
Finally, I would like to encourage you to support your clients with reviewing their arrangements particularly those involving related parties to ensure the arm’s length nature can be substantiated.
Director ID
For the next topic we have an important due date looming.
As I’m sure you realise all existing directors, including directors of a corporate trustee of an SMSF, are now required by law to have a Director ID by 30 November 2022.
New directors are required to apply for their director ID prior to their appointment. This means if any of your clients are considering setting up their SMSF with a corporate trustee, they will need to apply for a Director ID before they register the fund.
We estimate that there are around 690,000 directors within the SMSF sector. More than 330,000 of them have already got theirs which is a great start, however there is still have a long way to go with around 389,000 directors yet to apply.
The fastest way to apply is to use the myGovID app to log into the Australian Business Registry Services website. There is also an option to apply over the phone.
Directors must lodge their own application as they are required to verify their identity, authorised tax agents and other intermediaries are unable to apply on their behalf.
We know obtaining a myGovID has been difficult for some people, particularly older Australians as they might not have digital identity documents.
In these circumstances, we are providing them with access to alternate non-digital application channels on the phone or in writing. Additional certified documents are required for these options, so the process takes a little longer.
As there is not a lot of time left before the due date, any support you can provide to your clients by sharing this message will be greatly appreciated.
Transfer balance account reporting
There is also a change on the horizon regarding the frequency of reporting for transfer balance account events.
Following consultation, we have decided to streamline transfer balance account reporting so from 1 July 2023 this means all events will need to be reported 28 days after the quarter the event occurred.
More timely reporting will ensure the correct personal transfer balance cap information is displayed on ATO online and help your clients avoid getting into an excess cap situation.
Changes to SMSF rollover and release authorities
As you know, from 1 October 2021, it also became mandatory for SMSFs to use SuperStream to rollover super to, or from, their SMSF.
To do this they must ensure their SMSF has an Electronic Service Address (ESA) which provides rollover services via SuperStream. Our website contains a list of SMSF messaging providers.
If trustees have difficulty in obtaining an ESA, they can contact us.
Where they have been unable to engage a provider that enables SMSF rollovers, we may approve their use of the former paper process. Where this occurs, they should let their SMSF auditor know they obtained our approval and provide them with the call reference number to avoid a contravention being reported.
It’s important to make sure your clients keep their details up to date for two key reasons:
Firstly, as a fraud control, we send an email or text message alert to individuals’ personal contact details when a fund attempts to verify the SMSF or member details, prior to performing a rollover. If any of your clients receive an alert and they didn't request a rollover, they should contact their existing super fund immediately.
Secondly, difficulties in making a rollover into your SMSF are often because the transferring fund may be unable to verify details such as the SMSFs bank account and ESA. If there is mismatch between the information provided on the request and the data the ATO holds the transaction will not be approved.
Our website has further useful information to help your clients prepare for making a SuperStream rollover.
Membership increase
Just a quick update on how the member increase is going.
The change in legislation allowing up to six members in an SMSF has now been in play for over a year.
The latest statistics show 768 SMSFs have taken up this offer and are now operating with more than 4 members. There are 540 funds with 5 members and 228 with 6.
Conclusion
This brings me to the end of my presentation today, so I’d like to thank you for attending and for the ongoing support you provide to participants in the sector.
As I stated at the start, SMSFs are an integral part of the super system in Australia.
To maintain trust and confidence in the sector it is critical for us to work together to ensure people enter the system for the right reasons and participate in it correctly.
Thank you.
Speech delivered by Assistant Commissioner Justin Micale at the CA ANZ National SMSF and Financial Advice Conference.