Gregory F Parkin
GPO Box 6
Canberra  ACT  2601

26 October 2012

Manager
Benefits and Regulation Unit
Personal and Retirement Income Division
The Treasury
Langton Crescent
PARKES ACT 2600 
Email: strongersuper@treasury.gov.au 

Dear Manager
SMSF auditor registration regulations 
These are comments on the exposure draft Superannuation Industry (Supervision) Amendment Regulation 2012 (No. ).
In subregulation 9A.01(4), omit “subsection(2)” and substitute “subregulation (2)”.
As a matter of policy, you may wish to supplement paragraph 9A.02(a) of the draft regulations so that it extends to supervision by an approved auditor of a self managed superannuation fund before 31 January 2013 (at which time nobody could have been an “approved SMSF auditor”).   Item 70 of Schedule 2 to the Superannuation Laws Amendment (Capital Gains Tax Relief and Other Efficiency Measures) Bill 2012 has no application to supervision by an approved auditor of a self managed superannuation fund before 31 January 2013.  Paragraph 9A.02(b) allows ASIC to fill this gap by case-by-case decisions (and it could give some certainty by publishing a policy on this), but there is scope to give greater certainty by the Regulation.

Yours sincerely

Gregory F Parkin