Smarter SMSF offers a complete suite of SMSF investment strategy documents to implement and regularly review ensuring compliance with the super laws.

SMSF Investment Strategy

The SMSF investment strategy should be written and must be regularly reviewed to ensure that it continues to reflect the purpose and circumstances of the fund and its members.  Any decisions made and reviewed by the trustees should be documented and maintained for a minimum of 10 years in accordance with the record-keeping requirements.


When preparing and reviewing an SMSF investment strategy, the trustees must take into account the personal circumstances of all the fund members, including their age and risk tolerance.  Super laws require that the trustee(s) consider:
  • diversification (investing in a range of assets and asset classes)
  • the liquidity of the fund’s assets (how easily they can be converted to cash to meet fund expenses)
  • the fund’s ability to pay benefits (when members retire) and other costs it incurs
  • the members’ needs and circumstances (for example, their age and retirement needs).
In addition, the trustees must consider whether to hold insurance cover (such as life insurance) for one or more members of the fund.




Following completion of the order, the following documents will be generated as part of the completed order:
  • Investment Strategy Report;
  • Trustee minute accepting and adopting the updated investment strategy
  • Single Asset / Heavy Asset Concentration minute
Review Statement
Following completion of the order, the following documents will be generated as part of the completed order:
  • Investment Strategy Review Statement; and
  • Single Asset / Heavy Asset Concentration minute


Order your SMSF Investment Strategy documentation using our popular and cost-effective subscription packages, or simply pay-as-you-go (PAYG).

PAYG – $176 incl. GST 


or login if you are a member.

Create SMSF Investment Strategy documentation online, delivered instantly

Smarter SMSF provides the following documentation as part of their investment strategy suite:

  • Investment Strategy Report – to be used when creating a new investment strategy for the fund in accordance with SIS Regulation 4.09.
  • Investment Strategy Review Statements – to be used when the trustees need to undertake a regular review of the investment strategy, linking back to the initial investment strategy report.
  • Single asset / Heavy asset concentration minute – to be used where the trustees have a lack of diversification in the fund that requires additional evidence as to the decision made by the trustees to invest in a particular way.


Generate an SMSF Investment Strategy report for a self-managed super fund (SMSF), which formulates and gives effect to risk, diversification, liquidity, the ability to discharge the fund’s liabilities and the requirement to consider insurance cover for one or more fund members.

The following documents will be generated as part of the completed order:

  • Investment Strategy Report;
  • Trustee minute adopting the investment strategy; and
  • Single Asset / Heavy asset concentration minute (where indicated)

Review Statement

Generate an SMSF Investment Strategy Review Statement that satisfies the requirements of SIS Regulation 4.09 for the trustees having reviewed the existing strategy and have considered the areas of risk, diversification, liquidity, the ability to discharge the fund’s liabilities and the ongoing requirement to consider insurance cover for one or more fund members.

The following documents will be generated as part of the completed order:

  • Investment Strategy Review Statement; and
  • Review of Single Asset / Heavy asset concentration minute (where indicated)

Single Asset Class / Heavy Asset Concentration

Where the fund has a lack of diversification due to investing within a single asset or single asset class, you can select to generate an additional trustee minute demonstrating why inadequate diversification meets the fund’s objectives and personal circumstances of the fund.

Currently, you can generate a template to be completed by the fund trustee(s).  We will in the future allow for key questions of the various requirements within the superannuation laws to be answered that will generate an investment strategy report (NB. will need to consider licensing issues within this option).

To start ordering, simply follow these steps:

  1. Sign up to the Smarter SMSF platform (it’s free).
  2. You will receive an email with your login details.
  3. Once logged into our platform, select ‘Documents > Create New’.
  4. Follow the prompts, review & submit your order.
  5. You’ll have the order instantly delivered to you in less than 5 mins.

Need assistance?

If you require help with ordering your investment strategy SMSF documents, get in contact with us via live chat, by telephone on 1300 95 94 76, email

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Document Packages

We recognise that practices come in all different shapes and sizes, and that’s why our Create document packages have been developed as a bundle to suit the size of your SMSF business. Our document packages start at $180 p/m for ANY 25 docs p/a and provide a substantial saving monthly.

To work out how many documents you might need for your business, try our document calculator that can help to determine the package that is right for you.

The following sample documents are available:

  • SMSF Investment Strategy Template
  • SMSF Investment Strategy Review Statement
  • Single Asset / Heavy Asset Concentration Review Minute

To view a sample:

  • Sign up for free to gain access to our platform.
  • View sample documents from our Knowledge Centre.
  • Order documents on a PAYG basis.


Other references


Want to know more about the SMSF Investment Strategy documentation that is available through the Smarter SMSF platform?  You can watch these webinar recordings to find out more about how we help trustees to comply with the requirements within SIS Regulation 4.09 that apply to SMSFs.

This webinar explores the:

  • state of play with investment strategies
  • the regular review requirement for investment strategies
  • the auditor’s role and observations
  • finding key lessons to build a compliant investment strategy
  • demonstrating the investment strategy documentation available on the Smarter SMSF platform.

Video Transcript

all right welcome everyone to today’s session where we’re looking at the topic of building your smsf investment
strategy documents so this is an area that we continue to get
um a lot of inquiry a lot of orders in respect to not only I guess the
establishment of investment strategies but then what is required on an ongoing basis as well so hence why we wanted to
cover this topic again just to keep you up to speed with what is happening and
in particular what we’re doing within the smarter smsf platform to assist you
around the process of investment strategies so you may be having
identified this yourself within your practice that there is a need to kind of pick this up you’ve probably or more
likely potentially got some feedback through Auditors in respect to the
minimum expectations around what they would like to see in comply fights with
CIS regulation 4.09 which that has naturally stemmed from the ato’s
guidance that we’ve seen published a couple of years ago so what we’re going
to do is take you through I guess the various stages to this so that state of
play with investment strategies uh the context of the regular review in
particular now many of you have gone through this stage of getting investment strategies in play and then it’s well
what do we need to satisfy in the context again of sysrig 409 around the
fact that we must regularly review the investment strategy we’ll touch on the obligations that we see within the regs
in particular what the Auditors are looking for and some of their observations where these key lessons
have actually come from we’ll then jump into a bit of a live demo around what is
available within our platform and and utilizing the Integrations as well and
then just wrap up in respect to just a few issue a few issues considerations uh
and how our subscriptions might be able to work to assist you in the preparation update and reviews of investment
strategies as well so we’ll take the hour to really give you a up-to-date
context in respect to this particular topic so let’s go back and really understand
where this has come from and some of you may have seen this we spoke about this at our smsf day events earlier in the
year but a lot of this goes back to the initial concerns that the ATO had on the
diversification requirements around a targeted number of limited recalls
buying arrangers that had 90 or more single asset concentration within residential property now what is
interesting with this is this was a direct response to the Council of
financial Regulators providing a report to government in respect to the use of
Leverage inside of superannuation and we have just seen in September of 2022 the
council Financial Regulators provide a further report that is the three-year
review to this initial review so whilst there has been no real
um inference by the tax office that they would be looking at this as an issue
again like when they wrote to the 17 700 trustees in that respect and the
related Auditors in what they should be looking for we do see this report now having Arisen
again that may therefore look to see the ATO they could if they wanted to now
look to the information that they have obtained through the council Financial regulators and undertake a similar
scenario if they felt it was warranted so we haven’t seen anything that would support that to be the case but again
they had that ammunition available there should they wish to do it it might not be property it might be within
cryptocurrencies for example or other areas where they may see some emerging
issues and just want to ensure that trustees are adequately managing those risks in particular around single asset
concentration and it was from all of this that we then saw the ATO expand out
its narrative on the requirements to satisfy CIS regulation 4.09 so you can
always go back to that updated guidance on their website
qc23323320 and again it talks about that expectation of what needs to be included
and in particular the importance of giving effect to the whole of the fund
circumstances in formulating the investment strategy of the fund and it’s only when you start to drill down into
the information that you see in these statistical summaries do you see the
um how much asset concentration in certain pockets of the industry
um actually plays out there so 43 percent of funds have at least 80 or
more in a single asset class so that’s not just property that’s enlisted shares we know smsfs with that kind of comsec
mum and dad index around the bhps the Commonwealth Banks the nabs and so forth
even those funds have specific risk within the Australian equities Market just as we’re seeing in the in more
emerging areas of like I said before cryptos and and the like as well so how we deal with all of the requirements
risk liquidity diversification these are all parts of the evidence chain that we
need to incorporate into our investment strategies so what is really important to remember
now is is again we’ve kind of over the last few years we have seen a large
number of firms in particular really reset the way in which investment
strategies have been set up and therefore now going forward how we need
to manage that review process so what the ATO have made particularly clear
here is that the expectation of an investment strategy is that it is not
set and forget and the minimum requirement here is that we have an
imposed obligation on the trustee to regularly review the strategy to ensure
that it meets the current and future needs of the funds members taking into
account the personal circumstances of those and the ATO here when we think
about this regular review it is more than just contemplating whether we need to do it at least
annually because there will be additional circumstances that the ATO
has published here that say we expect or we would see it being prudent for the
trustee to prompt a review of the strategy in a range of other matters and
that is not just as part of the annual compliance requirements it would also be where there is a market correction it
would also be where the fund has a new member or members that are being added equally where the fund has members that
may to be departing and then also when a member would commence an income stream
and again in that instance we’re seeing additional liquidity requirements that
would need to be given consideration to to ensure that the pension obligations
at least the minimum there may be larger amounts than that but again we’re evidencing each of those different
pieces to a potential jigsaw of what reviews could look like throughout a
particular income year so as I said before the ATO as an absolute minimum
expects the trustees to review that strategy at least annually and that they
would document that they have undertaken this review and any of the decisions
that have been made as a result of that review having occurred so that’s where
we get to our um our annual review where our annual accounts we might see that just
Incorporated generally into the trustee minutes you may want to provide some
other formal documentation to support that there has been a review and then
the actions that have been taken if there are no specific actions and we
have adequately considered all of the elements as we’ve formulated in the initial in investment strategy we’re
linking it back to the investment strategy initially then we would be naturally satisfying the requirements of
CIS rig 409 and this is really what the auditor is looking for so they have I
guess their own checklist here and guidance from the regulator to ensure that they have met all of the investment
strategy requirements for that relevant income here so what they’re going to be looking for is that the fund has an
investment strategy in place and that investment strategy is documented even
though there’s no formal requirement for it to be documented within the regulation but the auditor isn’t going
to be able to audit the trustees head to understand how they are adequately
incorporating all of the requirements in sysrig 409 so we need to have a documented strategy and it needs to have
considered all of the factors that are set out within that CIS regulation now
the funds Investments then will be tested to ensure that they are falling
in line with that strategy so they are within the allowable ranges or if ranges
are not being utilized that those material assets that would form part of that Fund in particular where we have a
heavy heavy asset concentration ensure that they are listed and therefore the
auditor would be satisfied on that front and that is what the ATO says is an acceptable way in doing so and finally
we can demonstrate that there has been a review undertaken at least at some stage
during that relevant Financial year the question then is is what other things
may have occurred during that income year that might heighten the need to
undertake more than one review during the year so have there been other events so we’ve spoken about previously the
impacts of covert and what that might have had in respect to Market Corrections and or cash flow
requirements in the fund whether we’ve had new members they’ve maybe moved to retirement income streams
recognizing that detail for investment strategy purposes is critical here from
an ongoing compliance point of view so and I go back to again the same comment
that I made earlier here the fact that this is not set and forget so it is not just about let’s get the house in order
this year and then stick it back in the draw and not have to worry about it it is incumbent on trustees to ensure that
this information is provided on an ongoing basis because it is an ongoing requirement of the audit as we’ve set
out on this particular slide how each of those individual elements of CIS rig 409
are complied with so let’s now jump over to having a look I guess what we’re
observing and again we shared some of this um at our smsf day earlier this year
around where we are seeing a lot of the activity in the investment strategy
space around documents on our platform in particular so first and foremost we continue to see the investment
strategies being updated moving on from this initial strategy making sure we’ve
kind of got all the deficiencies that are in there and now remedied or where
they actually didn’t exist we actually have now got that information populated where then we have asset concentration
or single Asset Risk we then want to ensure that we adequately cover off on
this for the purposes of the audit so again we’re going back to the way in which the ATO approached this issue with
those lrbas the 17700 that said show us
how you are managing the requirement of diversification when it is clear that
the fund has a lack of diversification the role is not to tell you whether this
is an appropriate investment or not what but how are you managing that risk and
the way in which we can demonstrate that is through the addition of a trustee minute or incorporating that into the
investment strategy ordinarily and it’s here that we’re seeing Auditors increasing that level of activity
highlighting these own things whether we’re seeing it being reported management letters or whether we’re
seeing in some other form because obviously if it’s not addressed in the second year after it’s been raised in a
management bladder in the first year then we can potentially get into contravention issues and this is not
only managing the risk of the auditor and the ATO here and the auditor is
gatekeeper but it’s managing their own risk as well because what they don’t want to see or they don’t want to have
happen is seeing the risk then come back to them in a range of cases that we’ve
seen a couple of years ago bumgartner and the Cameron bear case where all ultimately without the observations of
the investment strategy understanding the risks that were inherent in particular assets it left the Auditors
exposed where the trustees sought to recover that loss from them so a couple
of well-known orders in our industry still highlight these very issues around
investment strategies and I’m sure you are having these conversations yourself with Auditors or if you’re an auditor in
your own right you’re asking these things of um trustees and or their service
providers to ensure that these are sufficient for the purposes of signing
off an audit each and every year and therefore the way in which we have tried to work is to fill some of the gaps that
we see in the marketplace and this is where we built out our comprehensive investment strategy and where we’ve
Advanced that to incorporate things such as the asset concentration and then also
through our investment strategy review statement as well so what happens if we
do get to the point where we have a breach so it is quite simple because we
would simply in the first instance expect to see an updated investment strategy the auditor should be working
with you to say there’s a gap here get it fixed get the trustees to complete
and sign this put in place trustee minutes where we might need to consider diversification issues and away we go
now what is important to remember here from an order perspective is there’s no Financial threshold test here so a
contravention is a contravention is a contravention when and how we get to the contravention
though is a different story because the auditor here is only going to need to Lodge an ACR notifying of the breach if
it meets that criteria which as I touched on earlier the criteria is going
to be met if the auditor has identified the same breach from a previous income year so again highlighted through that
management letter and it’s been repeated again okay so where it remains unrectified
then therefore we will see that contravention get reported so in most
instances you would hopefully find that this wouldn’t be the case we would work with the auditor to get this information
up to date and that’s why we kind of still see this steady stream of documents come through our platform
because of the fact that we’re seeing I guess adjustments and fix-ups because of the potential compliance Gap here as
well so there are a number of reference points that I just want to take you to a
highlight that set out what you need to ensure and what we’ve really relied upon
in building our smsf investment strategy documentation so one quite clearly funds
deed ensuring that it allows for not only the requirements of the investment strategy it is a covenant within the CIS
act to prepare formulate manage review the funds investment strategy and
therefore it it’s expected that that would be incorporated into the deed as well we’re looking at trustee Powers
what the fund can and can’t invest in etc etc we’ve spoken a lot already if we
move over to the right at the top that there is an ATO and audit expectation
now imposed on the industry really raising the bar and setting a new
standard in what is expected in producing smsf investment strategy
paperwork and a lot of those lessons have really come out of apra guidance so
I did a lot of work with the ATO back in 2018-19 when this was very much at the
Forefront of our industry and a lot of the feedback that I provided to the ATO
was really repurposing a lot of the guidance that is applicable through SPG
530 the Prudential guidance that is relevant to registered super entity
trustee so Trustees of apra regulated funds and in that regard it was quite
easy to be able to transpose those requirements into an smsf context and
that’s really where the ATO finalized its guidance in building in essence this
different or sets of expectations under each of those requirements set out risk
liquidity diversification etc etc so we’re looking at the same set
of requirements within section 52 within sysrig 409 so it is quite easy to be
able to transpose that information without the ATO having to start again and if you are in the provision of
advice to trustees then quite clearly we have Asic guidance that we would be
referring to as well and we’ve got report 575 that speaks to the way in
which advice is provided to Trustees of smsfs and how we can continue to improve on the experiences and the way that that
advice is provided and in particular there was was a heavy focus on property
and the use of lrbas in the provision of that advice and the expectations of what
would be required as well so let’s now go over and have a look here and spend
some time just helping to understand how and what you can do in terms of
ordering documents on our smarter smsf platform so got a number of tabs open
here but I’m going to kind of jump around to go through and do things so
the first thing here um is we do have the a number of documents that are available in respect
to the investment strategy so we have our investment strategy report ordinarily so you’ll be able to produce
that investment strategy report you’ll be able to produce the trustee minute where it’s relevant and then we also
have the ability through here to integrate with both simple fun 360 and
class now for those of you that may be super mate users you will be pleased to
know that over the next coming weeks we are about to start that integration so
we will have all three Integrations in the new Financial in the new um calendar
year I should say we hope to have that up and running and with a number of our members that are already super mate
users will be beta testing with them if you would like to be a part of that you can shoot us an email and we can have a
look at potentially doing that as well the same principles that apply here in respect to the investment strategy for
class or bgl users um will obviously be replicated from a super mate perspective as well so we do
have um really three key documents that we have to be able to support you here our
standard investment strategy our investment strategy single asset or asset concentration minute so you may
have other investment strategy document that you’re using so you may want to order that Standalone which you can do
it will generate as part of this pack here and also in respect to the review
statement if you do acknowledge that there is asset concentration risk this
document here is simply Standalone if you do have an investment strategy otherwise so what I might do here is
just jump to our knowledge base so you do have in here the knowledge base that you can access our sample documents and
the like and you can see here you can you’ll see that it is one of the more popular things that we’ve got on the
site here at the moment you can simply search in respect to the investment strategy you can also go and click on
the platform and then go to sample documents there as well and it will then come up under the sample documents and
you’ll be able to find copies of those um there as well so I might I’m just going to go go back to the investment
strategy here the other things we do have a number of videos and webinars and
stuff that we’ve run in the past um that you can always go back to and look at as well so when we look at the
investment strategy document here and I might come back to this in in a bit more
detail but the sample here will give you not only the template that gets crowded
but that trusty minute and so forth that is being adopted as well and again in
the single asset so again we could just put asset concentration and you can see
here the sample document or we have videos that we might work through and
explain this in more detail or even screenshots and so forth and things so you can always go and really understand
what have we actually covered and does it help me in ordering the documents
that I need to get ordered for my clients um so let’s now go in to these
particular documents and just show you around actually what I might do first is if we click order now there is quite
clearly a number of um things that need to be input around
that fund which naturally if you have an integration with class or bgl you are
going to be saving time by actually using that integration rather than
having to manually fill that out but we understand some people still obviously
do that approach as well so a few things here just to note as we populate I won’t
go through all the key detail there we are looking at it in the context of a new fund or an existing fund if it’s a
new fund that’s fine if there’s an existing fund we’ve still got some of the references back we will be turning
this off next year we do recognize that some people are still behind in getting these things done but we are also asking
in respect to different funds uh here regardless uh that there is uh different
questions so is the fund even though they might not be receiving a letter are
they investing in a single asset class so a lot of the things that we’ve been speaking about already if you answer yes
then it is going to produce some documentation trustee minutes that
support the type of investment that is in here okay so the other thing that
we’ll be adding into here that we do have in the Standalone minute is is around the cryptocurrencies so there
will be some changes you’ll see early in 2023 that will just update and reflect
um some of the different asset classes that are available you can then see how we want to Define how that report will
be provided so if we go into the investment strategy template here again
we have the ability to either produce the asset ranges by um percentage by
dollar amount or by um or by listing the different assets so
if I go down to that particular one there you will see in here we have that mix done by percentage range here so
again based upon the response that you have in the form it’ll transpose
the appropriate range or the appropriate table here on that answer that you
choose in that particular outcome so if it’s a percentage then you go from there so it is a fairly Standard Process if we
look at the integration here I’ve got the class one here you can see once you’re connected you can then create
that investment strategy document and that investment strategy document will then allow you to choose the fund from
that integration that you have connected and then that information is naturally going to populate in uh it’ll be just my
luck that I need to disconnect and reconnect yes it is um and then similarly I guess if we jump
across to bgl whilst I go through and just reconnect this
that same principle will apply in here you will go in and you will connect to
order the documents and then once you are in here you will then be able to equally type in investment strategy and
then you will be able to choose from the list of clients that you have in here
and then it will populate the information that it knows so if I just
go down to type where’s one that I need
to um uh and I’ll just reconnect this whilst
that’s happening so same principles it’s just giving access and then obviously the feed of
data will come through so here you can then see all of the information that is populated around the trustees and then
it’s just filling out the questions that you need to be able to demonstrate the
type of document that you want as well so just a little tip here um I’ll just delete that address for the
obvious reasons but if you um if it fills out as a particular way
just hit space at the end click the address up validates which means that as
you go down in different areas you then have it appear from that drop menu so in this instance we’re just choosing the
relevant dates and so forth so we’ve got all of the fields now done in respect to
this particular order for a new fund we’ll simply hit next and then it will
allow us to review and then submit that order so a couple of quick points here
to note is natural actually I’m using this in an administrator Administration
level so there is no price here if you are a member the same principles will
apply so if you have a create document subscription package it will bypass the
order here and simply reduce that order off your existing counter that applies
for that 12-month subscription period uh if you are ordering on a pay-as-you-go
basis then the price will appear here as will a credit card payment that will you
will then pay and once that has occurred you will then simply hit order now so
the same principles apply inside um the smarter smsf platform as well so
what you will do again using that integration connect order the documents
you can see here it’s now got the thank you it is then moving across to the
completed orders area and then there will be a series of emails that will come and confirm to you that that order
has been processed so if I just jump across my email we should see some confirmations so we’ve got our smsf
confirmation here that order and then we will see that order once it has been
generated also link to you so you can simply hit refresh as you go along and
once that order is done it will come and sit here as a completed order for you to be able to download at any point in time
as well so again you can see here I’ll just pick my fund um again we just simply select our fund
and then we can go through and do the full importation of the information the
trustees and so forth addresses and the like and then it will allow us to go
through and apply that same approach as we just did with this order as well so
again you’ll see once that Imports completed all of the document in here has been then done and allow you to move
forward so same thing there fairly straightforward in that approach and as I touched on before you can do that not
only in respect to the um simple fund and class Integrations in here but you
can do it across the asset concentration minutes you can also do it with our
investment strategy review statement and the review statement is something that
we built off the back of um the fact that we see more and more
people wanting to document that change in respect to the review so what we’ve
done in a similar vein to the way in which the investment strategy document has been produced is we have connected
the investment strategy to the actual investment strategy review statement so
you can see here we have a previous report prepared at that date so we’re
connecting it back and we’re talking about the review process so what is the reason as to why this review is
occurring and the reason why we are putting this together is because we can demonstrate
that we are then considering each of the different requirements so we’re looking
at statement of risk when considering diversification now it may be that there is no change and we will acknowledge
that but it shows that we have considered that topic and that there is no change that is required as a result
of it now if there was well then there is some further information there we may want to be changing the asset allocation
we’ve had some requests about maybe looking to populate this through the API so we will be looking to do that as well
we look at satisfaction around liquidity and the fact that we’re continuing to meet that requirement ability to pay
benefits and contributions whether we need to make changes for insurance and how they are going through that advice
process so this is a seven page document not a 17 or more page document that we
have with the investment strategy but it’s a nice neat tidy approach here to getting this documentation done by the
clients we’ve done this in a very deliberate way all of these investment strategy documents because it allows the
client to choose the thing that is most relevant to them otherwise they will
complete that information there and that is crucial subject to whether you are allowed to have these conversations or
not because if you’re an unlicensed then you are very limited in what you can and
can’t say which is why we build it this way because you can provide this you can
generate it and provide to the client and have them complete and we’ve done it in a way that gives enough explanations
for them to help read interpret and then tick the relevant box in 99 times out of
100 it’s very rare that we get down to this other option there as well so you
can see here we now have our document that we spoke about before I’m just going to click on that and then you can
see here that that document has been generated for that fund and then we have
all of the relevant information that has been populated in respect to the the
member and their objectives and stuff in here and then they again go through and tick all of the relevant things that
would be appropriate to them in this scenario so um there is one other I don’t know
whether I’ve got it in here or not you can see the adoption and the asset concentration in it like I said before
um if we just go up in here oops
we got our asset concentration minute so what we’ve got in here again this may
generate subject to the um whether you’ve ticked that relevant box or the drop menu so in here we’ve
got a recognition of the review we then have property as a single asset class
and the considerations as to why it would be appropriate for this fund and the resolutions that would follow from
that and again we’ve just got some guidance there and and the ato’s views as to why this is appropriate in these
circumstances to be producing um such information from a compliance perspective
so let’s now move back to our slides and
um keep going where do I need to go there share and share okay
so helping to prepare update or review so like I said I just touched on this very issue so if you are not licensed
what you can do is you can advise clients of the need to have the
investment strategy so you can identify this issue and say from a compliance perspective you must have a strategy you
can document the strategy so you can produce the template from our platform or via bgl for example there but the
filling out of that is obviously limited as to whether you’re licensed a lot now discussions
around diversification requirements and so forth is a bit murky so there is
um 7.1.33 a within the corporations act um that talks about whether and what
extent you may be able to talk but ultimately what you want to focus on is facts okay so facts are your friend
um because if you focus there then you won’t get in trouble so it’s about
really ensuring that you can provide that information and sure ensure that your client complies with that specific
obligation now the ATO does say be careful when obtaining templates as
these may not satisfy the rules so you kind of go well Aaron aren’t you just producing a template the concern that
the ATO has is is that you’re using something potentially out of a specific
software and all it talks about is that the trustee is considering risk liquidity diversification so it’s one
page and really isn’t worth the piece of paper that it’s written on and this is where we’ve then in bglers really we’ve
done a lot of work with them to say their role is not to be producing this
type of paperwork but allowing a document to be prepared that gives the
opportunity for the trustee to tailor to their specific circumstances okay so in that
instance you can clearly see yes we’ve provided a template but it enables them
to answer questions and choose their own adventure in essence around the circumstances that are relevant to them
and that is the critical piece to this process and that applies not only when you establish an investment strategy but
what you’re doing in the context of reviewing that on at least an annual basis as well now on the flip side if
you’re licensed then quite clearly the circumstances in which you can have these conversations are far greater risk
profile in inside Assets in super outside assets with super
um short-term long-term income needs client preferences and the like so
in terms of our suite of documents what do we have available like I said I’ve kind of explained and demonstrated and
showed you some of those before so investment strategy report is available as is our review statement and our
single asset concentration or single Asset Risk that does like I said include crypto and properties and the like we do
have the Integrations across both simple fund and class simple funding two fronts
so both through the software but also by our platform class for our platform and as I said our work to undertake the
supermate integration is to be starting in the next couple of weeks we also have
a series of unlicensed accountants letters that we’ve worked with um cath bowler from holy nevercoat law uh so
what we are doing there is we have a suite of documents that do incorporate the investment strategy report so if you
have any concerns around whether you the provision advice might rest with you or
not um you can ensure that the information and that the client has had the opportunity to seek advice and that
therefore based upon the information that they’ve provided you um you may then be looking to produce an
investment strategy for them maybe it follows off a statement of advice where they have obtained advice or they have
decided to not proceed but have given you the instructions to execute uh in an execution only framework these
unlicensed accountants letters are designed for that very specific purpose which we do have from new funds and
pensions uh investment strategies rollovers now under super stream where
they’re being instigated via your smsf software a number of those um so again that also forms part of The
Suite of documents that we have as well now where do we see this I guess if you
are looking at the context of investment strategies um what we have seen and observed over
the last 12 to 18 months within our own business is the fact that users come
down a couple of different paths in the way in which they might look to utilize investment strategies and a broad range
of documents with smarter smsf so the first journey is really there’s a specific need within the business and
this is where it might be with investment strategies and it becomes an economics game and we’ll show you an
example just shortly or we have this second Journey where this kind of dip your toe in the water do some orders do
a few more and then we will identify whether there is a Tipping Point for you
to actually say you know what we’re going to demonstrate to you why a subscription is better
than the way that you’re currently doing it and that even includes where you’re dispersing all this stuff straight through to your client so we did a
webinar earlier this year in June um we’ve got the link there we’ll share with you after today if you haven’t or
you want to find out more about it I would strongly suggest watching that it is a pretty compelling argument to both
of these particular Journeys but let’s go through and show you about this economics issue because what we’ve got
here is Jackie wants to upgrade all of her clients investment strategies she’s got 80 clients if she did them through
US she’d be spending about twelve thousand dollars a year plus GST 80 documents at 150 now alternatively she
could cred I I purchase a create 100 document subscription 500 a month or
five thousand a year plus GST and what it does is it reduces down the average cost less than 75 a document
and it will give her an additional 20 documents and what people get caught up with a lot with the subscriptions and
this may be even when it gets to a next one which is 250 is but I’m not going to
use that many the reality is and this is the important
piece here is it doesn’t matter whether you use them all or not the economics
here is in the following bullet point by comparison in ordering via a
subscription the break even here for Jackie is 40 documents out of 100 on a
pay-as-you-go basis so even if Jackie only orders 60 in
total for the year she is going to be ahead from where she was previously
ordering on a pay-as-you-go basis so it’s kind of getting through that barrier to say yes but I’m not going to
use all the documents that is irrelevant if you can use them to an inch of its life the last one on the last day of the
subscription kudos to you you’ve absolutely rung it dry to the force
extent but the reality here is is that in most instances even where the
documents won’t be fully used the subscription benefit will be significant
and in this instance 40 is the break even um and therefore Jackie can engage in a
whole range of other documents that she would in essence be more beneficial as a
result of that she can then charge and quite clearly there’s no additional cost to her firm which gives her a much
higher margin than in term terms of the use that she obtains from that document
subscription so there’s the list for you just in respect to what we have available and all the different pricing
points on a monthly or annual subscription so if you do have any questions you can get in contact with
David um who again can walk you through an analysis of what it might look like inside your firm we’ve got some guides
on the bottom of the table there about how many funds you might have but again we can have that discussion further with
you one of the things to note that might be a little bit carrot for you is that
we have launched today our Black Friday sale so um we do have on our document
subscriptions 25 off on our credit 25 credit 50 and create 100 packages
available over the next 72 hours through to Friday the 25th so we don’t usually
give discounts out on this stuff um so I would suggest if it is something that you are contemplating we’ve got a
dedicated page there smarter forward slash break Friday and you can have a look at the specials that we do
have available both from a CPD point of view and also with our document
subscriptions so key takeaways I guess from today’s session evidence evidence
evidence document document document around the support with investment strategies and therefore the reviews is
really this next phase around CIS compliance it now has gone more than just a few
standard paragraphs that come out of your smsf software and the expectation here now is the importance of how we are
demonstrating the obligations set out with CIS reg 409
and then the continued obligations of that each and every year and the events
that may occur during that year that would require a review to occur it puts a greater onus on trustees and
therefore maybe the role that you play to remain active in their assessment of
the fund’s performance against the objectives so we’re trying to kind of shift the needle many financial advisors
obviously are looking at alignment of objectives to fund performance to help meet retirement goals this is the very
essence of investment strategies and therefore we can all play some sort of
role in that process to ensure that trustees are investing for the right
reasons that allow them to measure and monitor where they want to get to for
retirement and our focus and one of our values in smarter smsf is being adaptable and Nimble so what we will
continue to do is build Solutions out that move with the regulations that move
with the legislation but most importantly it’s not only that specialization that we have but it’s the
leverage that we can get on the technology as well that enables you to
save time to save money and most importantly focus on what you do best with your clients as well so that is it
if there are any questions that people may have I’m happy to have a conversation about those now we do have
two final sessions for the year we do have an update around our CPD Solutions
including some updates that we’ve put through in our smsf foundations course uh on the 29th of November and our final
quarterly technical update for the year the changing face of smsf so thank you
to everyone who has uh joined us today like I said if there are any final questions please uh feel free to ask now
I’m happy to hang around for a few minutes otherwise have a great rest of the day and week and I look forward to
you catching up at one of our events in the not too distant future take care and bye for now

This webinar explores the:

  • The ATO letters about diversification issues
  • Investment strategy requirements within the super laws
  • licensing considerations providing an investment strategy to an SMSF trustee
  • documentation available to support trustees to comply with the investment strategy requirements.


Does an SMSF need an Investment Strategy?

Yes, the covenants within section 52B of the SIS Act (super laws) requires that the trustee(s) of a SMSF to have an investment strategy.  This sets out the fund’s objectives and specifies the type of investments that the fund can make.

How regularly can an SMSF change its investment strategy?

There is no legislative requirement that specifies how often an SMSF’s investment strategy should be reviewed or how often it can be changed.  
The super laws require a fund to regularly review the investment strategy which at a minimum would suggest that the trustee(s) review annually as part of the fund’s ongoing compliance requirements, giving consideration to any change in circumstances and the fund’s overall objectives. 
A change in circumstances could include (but not be limited to):
  • the acquisition or disposal of a material fund asset (e.g. with heavy asset concentration or as a single asset class);
  • adding or removing a fund member;
  • a member commencing a retirement income stream (i.e. pension);
  • where a member dies or becomes incapacitated (disability);
  • a change in marital or relationship status – e.g. marriage or divorce;
  • a change in the financial needs of the members of the SMSF;
  • as a result of significant market volatility; or
  • where the trustees are considering new investment activities not allowed for under the current investment strategy.

You should prepare the Investment Strategy Review Statement to support a review based upon any of the above decisions.

What documents does Smarter SMSF produce for the Investment Strategy?

Investment Strategy Report
Following completion of the order, the following documents will be generated as part of the completed order:
  • Investment Strategy Report;
  • Trustee minute accepting and adopting the updated investment strategy
  • Single Asset / Heavy Asset Concentration minute
Investment Strategy Review Statement
Following completion of the order, the following documents will be generated as part of the completed order:
  • Investment Strategy Review Statement; and
  • Single Asset / Heavy Asset Concentration minute

We have an investment strategy in place, but only want to change the current asset allocation of the fund?

If the fund’s objectives and overall circumstances are not changing, but you wish to change the asset allocation within the investment strategy, you can produce a ‘change asset allocation’ document on the smarter smsf platform.

We have an investment strategy in place, but need a trustee minute to comply due to heavy asset concentration in a particular asset class?

You can create a stand-alone trustee minute that provides resolutions as to why to trustees believe a lack of diversification is appropriate to the member’s needs in meeting their retirement objectives.

The single asset class / heavy asset concentration minute covers:

  • Australian Listed Shares
  • International Listed Shares
  • Australian Fixed Interest
  • International Fixed Interest
  • Cash – short term and long term holdings
  • Direct Property
  • Property held through a unit trust
  • Cryptocurrencies, such as bitcoin

Does the Smarter SMSF deed permit all types of investments allowed under the superannuation laws?

Yes, the trust deed allows for any type of investment currently allowed under super laws, including areas such as crypto-currency, property development, etc.

Who needs to sign the Investment Strategy?

Each trustee of the SMSF will need to sign the investment strategy along with trustee minutes adopting that strategy.

Who will require a copy of the fund's investment strategy documentation?

Whilst there is no requirement to register or lodge the investment strategy with any government or statutory body, the fund will be required to provide a copy of the investment strategy to the fund auditor as part of the annual audit process.  
For record keeping purposes, the super laws require that the investment strategy and any related decisions (i.e. trustee minutes) must be kept for a minimum of 10 years.  

From the blog

Read our articles about investment strategies and investment-related issues from the Smarter SMSF blog.