The Association of Superannuation Funds of Australia (ASFA) has requested the commencement date for the SuperStream transition rollover period be moved back seven months to 1 February 2014, but for the full compliance date to remain at 1 July 2014.
However, under the ASFA proposal to the Australian Taxation Office (ATO) on superannuation data and payment standards, providers who are working together could elect (in consultation with the ATO) to begin the transition early.
The association suggested an initial set period during which trustees could nominate specific products and/or select only some rollovers to be sent via the new SuperStream system.
ASFA said the current timetable would increase implementation risks because SuperStream was always going to require 12 to 18 months of work from the legislation's finalisation. Given the delays in finalising legislation and the technical detail of data standards, the currently proposed dates are too ambitious, according to ASFA.
The association also identified the lack of an appropriate governance framework as one of the major uncertainties around SuperStream implementation, and proposed the establishment of a governance body that would "oversee the operations of SuperStream and the interoperability of 'gateways' in particular".
A significant unresolved matter impeding interoperability between gateways is pricing and whether there should be transaction fees between gateways, according to ASFA.
The question of whether there should be interchange fees for the passing of transactions between gateways could be a roadblock to the ability of potential gateway service providers to give pricing information to superannuation trustees, ASFA stated. The best resolution would be a 'user pays' solution similar to the way in which the banks' ATM network operates, the association added.
ASFA also requested the ATO provide more detailed information on exactly what would be required of super trustees from 1 July 2013 due to concerns that all trustees will need to be ready to receive electronic rollovers from this date. For some this would potentially mean systems will have to be completely redeveloped by this date.
If this was moved to 1 February 2014 it would not only allow more time for systems development, but also for trustees to complete 'year end' which would de-risk the process further, according to ASFA.
