minutes / MeetingS 26/2/2013
Minutes
Title: / SuperStream Technical Architecture Sub Group
Venue: / ATO - Level 12 52 Goulburn St, Sydney NSW
Event Date: / 26 March 2013 / Start: / 3.05pm / Finish: / 5:05pm
Chair: / Philip Hind
contact / Grace Ng / Contact Phone: / 02 937 48024
Attendees:
Names/Section / Philip Hind ATO
Chris Thorne ATO
Scott Jeffrey ATO
Ty Winmill ATO
Eliza Taylor (minutes) ATO
Graham Sammells IQ Group, ASF E-Commerce Group
Andrew Blair Andrea McIntyre MLC/NAB
Kyle Dunsire AMP
Francis Cox Industry Funds Forum (IFF)
Stevhan Davidson Sunsuper
David Kerr AAS
Jamie Hancock Australian Payroll Association
Frank Gilmartin Aurion
Stuart Heriot GBST
Joe Brasacchio Intunity
Grant Doherty Westpac
Frank Gilmartin Aurion
Apologies:
Name/Section
other attendees
next Meeting: / Friday 19 April 2013 Australian Taxation Office, Sydney
Placeholder 12 April – Teleconference only
Agenda item: / 1
Philip Hind opened the meeting at 3.05pm, welcomed members.
Topic: / Acceptance of minutes 08/3/2013Minutes haven’t been circulated. Ty will circulate minutes so the group can review.
Topic: / Review of Action ItemsAction Items were reviewed. A list of action items discussed are at the end of the minutes.
Agenda item: / 2Topic: / Review of Issues Log
Philip opened the discussion for current issues. These included:
1. Error handling – issue now resolved and closed
2. Unique Transaction Identifier – also resolved and closed.
3. Use of URL – to be discussed today, now approved as alternate electronic service address of FVS.
4. SPIN as USI – also resolved as approved as an alternate unique superannuation identifier. This has been published on ATO website:
http://www.ato.gov.au/superfunds/content.aspx?doc=/content/00349293.htm&pc=001/149/032/006/010&mnu=52961&mfp=001/149&st=&cy=
5. Rollover message validation issue - to be resolved next week.
6. More sample scenarios related to validation rules should be published after testing is carried out.
7. Message handling – the group agreed this issue was now redundant.
New issues
1. David raised Super TIC MIG still not finalised and is needed prior to testing.
2. Steve raised that the “pilot” and “end state” message requirements are different for Super TIC. This is to be rectified upon release of the MIG.
3. Steve also queried late entries into the pilot for Super TIC.
4. Grant mentioned that the errata should contain long detailed descriptions as this is what’s reflected in the schema.
Action item: / 1 / Responsibility:Due Date: / 12 April 2013 / ATO
§ ATO to ensure consistency in schema descriptions.
5. Inconsistencies in wording between MIG and taxonomy:
“Super” as per MIG pages 11, 13, 14.
“Superannuation” as per taxonomy
Action item: / 2 / Responsibility:Due Date: / 12 April 2013 / ATO
§ ATO to update MIG (pages 11, 13, 14) and / or taxonomy with the word “super” or “superannuation”. Need consistent wording.
6. Where a fund has 1 product and 1 ABN do they need a USI?
Yes – where there is no USI, it would just be the ABN plus 3 digits.
Where a fund only has one product, can it be optional to include USI?
Note – MIG states it is optional, however where a message received doesn’t have a USI it may be more difficult to look up on FVS.
Action item: / 3 / Responsibility:Due Date: / 12 April 2013 / ATO
§ ATO to ensure consistency in Rollover MIG as to whether the USI should be mandatory or not.
SMSFs were discussed as they will not have USI’s.
For rollovers, USI is optional but ABN is mandatory.
Does this make SMSFs get an ABN where they do not already have one?
SMSFs may use ABN plus 3 digits. Where a SMSF has more than one product (e.g. where a member has different pension and accumulation products) the pension account would be excluded from nomination.
7. On FVS, some products listed may not be allowed to accept rollovers (e.g. closed pension products). These should not be listed on the register.
It was suggested there could be a “flag” as to which products are closed to rollovers so then no reject message is required which would ensure efficiencies are maintained.
8. Are SAF’s included on the register?
Yes, each SAF listed separately on the FVS, there will be a separate USI and bank account for each fund, may have same service address.
9. Bulk payments was discussed, however it was concluded that it has already been logged on the issues register.
10. Where a paper request is received, can the reply be sent electronically?
Yes, will be added to our FAQ’s as this is a recurring question.
Action item: / 4 / Responsibility:Due Date: / 12 April 2013 / ATO
§ ATO to add FAQ regarding sending electronic responses for paper initiation requests.
Agenda item: / 3
Topic: / Testing Strategy
Testing strategy should be ready by Wednesday as a consultation draft.
Philip noted that the ATO is not providing a test environment.
Self certification document was presented by Philip and even though it is signed by the fund / trustee it will provide assurance for implementation readiness. It may be used for groups of entities subject to the same transition-in date.
Self certification may be used at a later date by regulator should an investigation or review be required.
Additional test cases were requested. Andrew Blair will provide details for their Test Director.
Action item: / 5 / Responsibility:Due Date: / 12 April 2013 / Andrew Blair
§ Andrew Blair to provide Ty Winmill with Test Director details from MLC/NAB.
Agenda item: / 4
Topic: / Data standards and security
It was opened to the group to nominate any other requirements to be considered.
Francis Cox was concerned that funds that have not been engaged in our co-design or walkthrough sessions, may struggle to understand their obligations and associated risks of the services and compliance.
Is more guidance required to assist these funds in categorising their risk framework?
Philip mentioned guidance from the Technical Architectural Sub-Group can be published but it is not the ATO’s role to provide advice on how to manage their own internal risk processes.
Funds will look to administrators to provide guidance as well as documentation from APRA as to how they will treat and assess risks.
This will be discussed with the SuperStream Advisory Council and whether a “Best Practice Guide” can be developed.
The ATO needs to be mindful that we are not creating a 5,000 page guide that will fit a group of funds. We need to ensure that the guidance being released fits the majority funds.
Kyle enquired as to whose responsibility it is where an upload of data is intercepted fraudulently – in order to rectify this error, is it up to the fund / gateway / employer?
The group discussed the possibility and it was concluded that the fund should be able to identify errors based on their own I.T. system capability within their “Risk and Intelligence” areas. E.g. where transactions (i.e. data messages from an employer) are inconsistent with previous patterns.
Employers engaging with gateways need to ensure there is sufficient security in place for data not to be interfered with. This is outside the Standard and is up to the employer / gateway / fund to ensure.
For example, Westpac gateway receives rollover request from MLC, but it states ANZ in the message header. This may signify potential fraud where the sender is actually MLC but the request message contains ANZ as the sender.
The gateway will not be opening and repackaging messages, therefore, unlikely the gateway will be able to identify fraud issues.
Action item: / 6 / Responsibility:Due Date: / 12 April 2013 / Philip
§ Discuss with SuperStream Advisory Council whether a “Best Practice Guide” can be developed to assist the less engaged / smaller APRA funds.
Agenda item: / 5
Topic: / FVS – inclusion of URL as an option
This week approval of the URL as an IP address was received. ATO website needs to be updated.
Will the ATO have a preferred option?
The group discussed the URL being more reliable than the IP address but will report back after implementation of FVS.
Funds will look at using the USI to accept and brake up messages that are received.
Action item: / 7 / Responsibility:Due Date: / 12 April 2013 / ATO
§ ATO to publish approval of URL being included on FVS
Agenda item: / 6
Topic: / New and emerging risks
Discussed above under agenda item 2.
One additional issue was identified:
Group requested release of AS4 schema and that it should be extended to include EbMS wrapper.
ATO will also look at providing examples of AS4 envelopes.
Group was advised about Grant’s message packaging paper which is up on the web – grant sent a link out to the paper.
Action item: / 8 / Responsibility:Due Date: / 12 April 2013 / Ty Winmill
§ Rollover MIG.
Also, the misalignment between the residential and postal addresses has been rectified and the legislation has been updated to include the residential address.
Out of session feedback was welcomed.
ACTION ITEMS FROM PREVIOUS MEETING
Action item: 1previous Minutes / 22022013 / Due date:
12 APRIL / Open
responsibility: / Ty Winmill
· Publish and circulate minutes from all previous meetings (8 March 2013, 22 March 2013 and 26 March 2013).
Action item: 2
error handling / 22022013 / Due date:
12 APRIL / Closed (but report back required)
responsibility: / Ty Winmill
· Examples drafted but need to be circulated to the group for website publishing.
· To be finalised this week.
· Ty to clarify:
o Errata publishing timeframe
o Additional examples
Examples include missing message content, invalid formats.
It was noted that where multiple event types are present, format must always remain as XBRL.
Action item: 3Unique Transaction Identifier / 22022013 / Due date:
12 APRIL / Open
responsibility: / Ty Winmill
· Guidance will be published to the TA Sub-group SILU site
· Ty advised scenarios will be published over the next week
Action item: 4
LARGE MESSAGING HANDLING / 22022013 / Due date:
12 APRIL / Open
responsibility: / Ty Winmill
· ATO seeking further data (from OASIS and other best practice groups) to progress this issue.
Action item: 5
WEBSITE / 15022013 / Due date:
12 APRIL / Open
responsibility: / Ty Winmill/Philip Hind
· Usage instructions may be useful for visitors
· Alerts for site updates haven’t been working, may need to look at alerts for “closed sites”
Navigation around site is presenting difficulty.
Ty welcomed feedback and guidance on document locations on the web site.
It was decided that the group was happy for the information being published to go out to a wider audience, i.e. industry associations, but clarity around issues is needed before hand.
Links to be re-sent to Joe in SILU.
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