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Managing compliance checks for investment strategy changes impacting SMSFs 

Aaron Dunn
By Tony Zhang
11 November 2021 — 2 minute read

With the ATO recently reminding trustees to regularly review the SMSF investment strategy, advisers can ensure regular correction processes is in place to better navigate the compliance review process for the fund.

The ATO recently provided a timely reminder (QC 67071) that SMSFs need to regularly review the fund’s SMSF investment strategy to help meet their investment and retirement goals. 

Smarter SMSF CEO Aaron Dunn noted the investment strategy is not designed to be a “set and forget” document, but rather a strategy that requires the trustees to continuously review the strategy to ensure that it is helping to meet the member’s retirement plans.


Mr Dunn said the regularity of when to review an investment strategy would shift depending upon the circumstances that surround the fund. 

This may be when a market correction has occurred, a new member joins or departs the fund, or a member commences receiving a pension. This is to ensure the fund has sufficient liquid assets and cash flow to meet minimum pension payments prior to 30 June each year.

“With the impact of COVID-19 over the past couple of years, addressing issues of liquidity and the expected cash flow requirements of the fund are a further example of when trustees would be conducting a review of the investment strategy,” Mr Dunn said.

“Triggers here would have been where rent relief was been provided, impacting the income inflows of the fund, and if loan relief was been sought (i.e. LRBAs) due to the impacts of the fund to meet its cash flow obligations.

As a minimum, the trustees should conduct a review of the investment strategy as part of the fund’s annual compliance requirements.

When conducting the review, this is not simply stating that the fund has reviewed the strategy in accordance with SISR 4.09, according to Mr Dunn. It requires a demonstration as to how the trustees have undertaken the review and any decisions made that have arisen from the review.

“It is this evidence that will be required for the audit to assess compliance with the operating standard,” he explained.

“It may also need to include how the trustees continue to comply with the diversification requirement where the fund invests within a single asset or has heavy asset concentration within the fund.”

The auditor will be required to check that the SMSF had an investment strategy in place for the relevant financial year that considered the factors within SISR 4.09.

“The fund’s investments during the relevant financial year were in accordance with that strategy; and the strategy had been reviewed at some stage during the relevant financial year.

“The fund’s auditor may need to notify ATO through lodgement of an auditor contravention report (ACR) where the trustees don’t comply with the investment strategy requirements.” 

This comes as Smarter SMSF had recently released an Investment Strategy Review Statement to address the issue of regular review for the fund’s investment strategy and ensure trustees can comply with the ongoing requirements of SISR 4.09.

Managing compliance checks for investment strategy changes impacting SMSFs 
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Tony Zhang

Tony Zhang

Tony Zhang is a journalist at Accountants Daily, which is the leading source of news, strategy and educational content for professionals working in the accounting sector.

Since joining the Momentum Media team in 2020, Tony has written for a range of its publications including Lawyers Weekly, Adviser Innovation, ifa and SMSF Adviser. He has been full-time on Accountants Daily since September 2021.

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