Submission – Proposed change to stamp duty disclosure requirements

SMC supports ASIC’s immediate proposed reform to fix the distortions created when large, one-off stamp duty costs are reported as a single‑year spike in Fees and Costs Summaries and comparison tools, like the ATO’s YourSuper tool. We note however that this proposed immediate reform does not fully address the fundamental misclassification of stamp duty – which is a Government tax, not a negotiable investment fee, and note the current disclosure rules do not require stamp duty to be reported on indirect property holdings but only on direct property holdings. Yet direct holdings typically deliver stronger investment returns to members, creating distortions in capital allocation across the system that may structurally impede the strongest possible long-term risk-adjusted returns for consumers. We therefore urge the fast-tracking of the announced full review of Regulatory Guide 97, which should commence straight away to enable careful and comprehensive consideration of these issues in their wider context.