Date posted: 14/02/2024

Joint submission on Miscellaneous Amendments to Treasury Portfolio Laws 2024

In the limited time available to us we have examined the Exposure Draft and offer the following comment:

We are concerned about item 32 (see Division 7 of Part 1 of Schedule 1 of the Exposure Draft Bill. We do not believe breaches of proposed Sec 254A of the Superannuation Industry (Supervision) Act (“SIS Act”) should be subject to administrative penalties as defined in Part 20 of the SIS Act. We hold this view because breaches of the proposed Sec 254A would be subject to significant penalties under Sec 285 of that Act.