Consultation Meeting

Draft MIGs Version 2.0

ATO 52 Goulburn Street Sydney 9 June 2015

Summary

Since October 2014 the ATO have been engaged in co-design with industry to include amendments, government Rollovers and Contributions into the data and payment standard.

The technical documents supporting this change were released for public consultation in March 2015.

However, the following topics required further consultation to enable finalisation of the updates to the standard:

•Transaction Reference Number

•Payment Reference Number to support the ATO

•The use of multiple service / action combinations in the government interactions

•The process for managing cutover to the industry standard, and implementing the government interactions

•Whether industry required an amendment interaction in support of Rollovers

This meeting was the first of three scheduled consultation meetings to discuss the issues, determine the benefits and costs associated with each topic and achieve an outcome around each of the issues.

Consultation will be completed in August 2015 to ensure a 12 month lead time before implementation.

Outcomes from the consultation will be referred to the SuperStream Reference Group for consideration, and then to the Commissioner for a decision on their inclusion in the standard.

Further consultation sessions are scheduled for 7 July 2015 and 11 August 2015.

To be ready for Consultation Session 2 on 7 July 2015, please consider the topics and issues raised and canvass the views of your organisation.

Please provide your answers to the focusing questions via Tuesday 30 June 2015.

MIG v2.0 Cutover Process

Participants agreed that it makes sense to have a longer cutover window for contributions than rollovers as contribution transactions involve a more diverse range of participants.
The value of a 4 week window for rollovers was questioned by some participants’ i.e. massive overhead for little value; others considered it was worth having a 4 week window as it will allow for the staggered management of the change. For example, potential to implement B2B interactions (existing participants) in the first 3 weeks followed by the introduction of government interactions (new participant) in week 4.
General agreement for all participants to be ready to receive messages in v2.0 by an agreed date but staggering the sending of messages during the cutover period.
General agreement to using FVS codes to indicate readiness.
The ATO agreed to prepare a consolidated timeline of cutover windows that sets out ATO deliverables for the cutover and other relevant releases (e.g. Super Match 2) for the next consultation session.

Transaction Reference Number (TRN)

Participants agreed the use of natural identifiers has not worked well for rollovers, it is difficult to reconcile what IRRs and RTRs have been actioned using natural identifiers.
Subject to clearly identifying the business benefit, the use of a mandatory TRN would be desirable.
There has been some resistance from industry participants with multiple registry systems as the cost/scope of work required to introduce a TRN would be higher than those with single registry systems
Natural identifiers have been found not to be reliable, as not all participants are able to properly populate them, particularly for contributions
Suggestion made to raise the level at which TRN is applied – raising this from contribution type to the member/context level was considered desirable from an industry perspective
The same rules for generating a TRN – currently a 22 character string item, could be the same rules that apply to payment reference numbers.

Payment Reference Number

Participants acknowledged the ATO needs a mechanism to differentiate SuperStream payments and accompanying payment messages from other ATO payments e.g. income tax, as Income Tax payments do not have an accompanying payment message.
Participants identified an additional option for the ATO, this being to establish a separate bank account for SuperStream transactions.
Participants indicated a strong preference for not taking a different approach for B2B and B2G payment messages.
It was noted that there are physical constraints associated with the use of leading characters (i.e. maximum of 18 characters) so the use of an additional 2 leading characters to meet the ATO’s needs would create issues for any participants who are already using all 18 characters.

Amendments

The ATO confirmed that the rollover amendment was de-scoped from v2.0. Initial industry consultation indicated that an amendment interaction would be unlikely to be used for B2B and the ATO has reviewed its position and anticipate the volume of USM Rollover amendments to be low so these transactions would be handled manually.
An industry participant indicated they would prefer to deal with the need for the amendment interaction now if it is likely to be required at any time in the future, rather than excluding it now and having to build it in at a later date.

Follow the fund information

Feedback from industry is required on the preferred approach for the fund obligation to provide the Commissioner with follow the fund information.
AB2Gerror message only for a government interaction, or
Mandatory use of SuperTICK for closed accounts.

It was acknowledged that neither of the proposed designs would address scenarios where Fund A makes a rollover to Fund B (USI 123) and Fund B allocates the rollover to a different product (USI 456) as the member provided incorrect details to Fund A when requesting the rollover.

Service /Action

Feedback from industry is required from industry participants on the ATO’s approach of using

different service/actions for government interactions but using the same B2B payload.

[Internal/External]

[Classification]