CAANZ and CPA Australia’s joint submission the Review of Your Future Your Super Measures – Consultation Paper has raised a number of concerns which include:

• Employers must face no penalty for administrative failures made by the Australian Taxation Office (ATO) if the employer acts in good faith when making superannuation contributions under the choice of fund rules.
• Trustees should have the right of redress to correct incorrect data published by APRA if it results in an erroneous adverse determination.
• The need to resolve considerations of whom relevant beneficiaries are, and how complex products such as ‘glidepaths’ are treated in the event of two subsequent failure notices.
• Uncertainty in relation to how rules such as non-arm’s length income and expenditure restrictions intersect with the BFID.
• Concerns in relation to the focus of the BFID on third-party payments.
• Conflicts with the sole purpose test, especially in the treatment of death insurance cover.