“Financial advisers are also subject to extensive disclosure obligations to ensure their clients understand and agree to the fees they must pay. We believe a similar obligation should also apply to superannuation funds who wish to collectively charge advice fees to its members.”

Furthermore, the submission stated that it should be acknowledged that a member of a superannuation fund may also pay for their own financial advice directly with their choice of financial adviser outside of their superannuation fund.

“In this instance, there will be a duplication of advice costs to that member. Importantly, it is also unclear if the ‘new class of adviser’ will have a role in providing ‘simple’ retirement advice under this reform,” it said.

“This could further drive an uneven regulatory playing field to provide the same scope of retirement advice between a financial adviser and the superannuation fund.”

Additionally, the SMSFA said that while it supports the policy intent to collectively charge to support superannuation fund members’ access to quality information and targeted guidance, it recommends this measure is paused until the remaining elements of the reform package are consulted on, and the issues raised in the submission are appropriately addressed.

It continued that it also has concerns over the absence of a framework for what is simple versus complex advice.

In regard to “allowed topics”, the association noted the consultation paper states that this is not an extensive list, and it believes consideration should be given to limiting the financial advice that can be collectively charged to members of a superannuation fund.

“We also believe what is ‘simple’ advice must be further explored and parameters set. For example, depending on the client’s circumstances, advice about contribution strategies can be very complex and require important tax considerations,” it said.

“Consideration must also be given to situations where the member may hold one or more superannuation interests outside of the superannuation fund that they seek advice from. Social security and superannuation can also be complex areas of advice, with changing benefit entitlements and thresholds. Yet, they would be relevant to the provision of retirement income advice for members nearing or in retirement.”

It continued that the allowed circumstances list should be no different from those that any financial adviser would be required to consider to comply with their best interest duty and ethical obligations to provide the same scope of financial advice.

“Consideration must also be given to how information will be verified for individuals outside the superannuation fund, such as the member’s spouse, including compliance with privacy obligations where the individual is not a member of the same superannuation fund,” it said.