ATO Looking to Challenge SMSF Trustees About Lack of Diversification

In a rare attempt to guide SMSF Trustees in how they should or shouldn’t invest the ATO has issued a news release about their intention to approach trustees who they believe have not got sufficient diversification in their SMSF portfolio. So it is time to review your strategy if biased to one asset class.

Does your SMSF investment strategy meet diversification requirements?

At the end of August 2019 the ATO intend to contact about 17,700 self-managed super fund (SMSF) trustees and their auditors where their records indicate the SMSF may be holding 90% or more of its funds in one asset or a single asset class.

They are concerned some trustees haven’t given due consideration to diversifying their fund’s investments; this can put the fund’s assets at risk.

They say further in the release that “Lack of diversification or concentration risk, can expose the SMSF and its members to unnecessary risk if a significant investment fails.

We’ll ask trustees to review their investment strategy and clearly document the reasons behind the investment decisions.

We’ll also ask trustees to have their documentation ready for their SMSF’s approved auditor for their next audit to help the auditor form an opinion on the fund’s compliance with these requirements.”


So what can you do:

It’s a time to be pro-active and not wait for the contact. Review your investment strategy and reasoning now and make sure it will stand up to scrutiny

6 Key Considerations for your SMSF Investment Strategy

Review the ATO guidance on Investment Strategies in a blog I did here:

SMSF Investment Strategy Explained

Understand exactly what your SMSF invest in:

What can my SMSF invest in?

Ideas on diversification that may help you understand why you need to diversify or to back your personal reasons for limiting your exposure to specific classes:

Best Performing Asset Class Annually for Last 20 Years

SMSF Investing – Understanding Home Country Bias

The added value of franking credits in a SMSF Portfolio

Understanding Currency Exposure When Investing Overseas in your SMSF

Are SMSF Investors really comparing Hybrids vs. Company Shares?

Everything you need to know about Property in a SMSF

BITCOIN, DOLLARS, GOLD: What Is the Future of Money?

SMSFs – allocation to international shares

How can you add diversification simply and cost effectively:

This is not a recommendation as you need to understand your own needs and that of your SMSF and to do your own research or get advice. this is just one example of how to access a broad diversification in a easy and cost effective manner.

Vanguard Diversified ETFs – A Game Changer for SMSF Portfolio Design

Are you looking for an advisor that will keep you up to date and provide guidance and tips like in this blog? Then why not contact me at our Castle Hill or Windsor office in Northwest Sydney to arrange a one on one consultation. Just click the Schedule Now button up on the left to find the appointment options.

Liam Shorte B.Bus SSA™ AFP

Financial Planner & SMSF Specialist Advisor™

SMSF Specialist Adviser 

 Follow SMSFCoach on Twitter Liam Shorte on Linkedin NextGen Wealth on Facebook   

Verante Financial Planning

Tel: 02 98941844, Mobile: 0413 936 299

PO Box 6002 BHBC, Baulkham Hills NSW 2153

5/15 Terminus St. Castle Hill NSW 2154

Corporate Authorised Representative of Viridian Select Pty Ltd ABN 41 621 447 345, AFSL 51572

This information has been prepared without taking account of your objectives, financial situation or needs. Because of this you should, before acting on this information, consider its appropriateness, having regard to your objectives, financial situation and needs. This website provides an overview or summary only and it should not be considered a comprehensive statement on any matter or relied upon as such.

Evans Dixon US Masters Residential Property Fund URF under scrutiny – Warnings were given 3 years ago

The Australian Financial Review has released an article (behind paywall) today focusing on poor performance of Evans Dixon’s internal funds marketed heavily to many of their clients. The main focus is on the fall in value of their own stock but equally on the heavily fee laden products such as US Masters Residential Property Fund (URF).

source AFR and Bloomberg

Well that’s almost exactly 3 years after another finance website, EVISER,  that I was very proud to be apart of, called out the fund as “A magic pudding, just not for investors” and “one of the most expensive managed funds we’ve ever laid our eyes on”. Here is that full extensive article written by John Nunan and Richard Livingston for Eviser in MAY 2016 and bear in mind that the fund was showing positive returns at the time but hiding its true colours. All data on fees and charges were relevant as of May 2016 but may have changed in the last 3 years.

US Masters Residential Property Fund: A magic pudding, just not for Investors

We explain why the US Masters Residential Real Estate Fund is one of the most expensive managed funds we’ve ever laid eyes on.


Fund: US Masters Residential Property Fund

Fund manager: URF Investment Management Pty Ltd (part of Dixon Advisory Group)

Closing date: N/A (fund is listed on the ASX)



Product type: ASX listed managed fund

Investment type(s): International real estate

Performance benchmarks: None

ASX code: URF

Minimum investment: N/A

Distributions: Semi-annual

Fund size (at 31 Mar 2016) $622m (market capitalisation)

Inception date June 2011 (listed on ASX in July 2012)

Performance (since inception) at 31 Mar 2016 11.7% per annum (calculated by Dixons based on share price performance, including dividends and adjusted for rights issues).


Investment management fee: 1.24% pa (plus GST)

Administration fee:  0.25% pa (plus GST)

Responsible entity fee: 0.08% pa (plus GST)

Custodian fee: 0.02% pa (plus GST)

Other:  listing fees, salary and wages recharges, office admin recharges, asset disposal fees, asset acquisition fees, structuring and arranging fee, debt arranging fee and handling fee (see table in article for more information)

Performance fee: None

Buy/sell spread: N/A (traded on ASX)

The Magic Pudding is a classic Australian children’s book that tells the story of a pudding that, no matter how often it’s eaten, is always available for its owners to eat next time they’re ready for a meal.

The US Masters Residential Property Fund (ASX Code: URF) is the magic pudding of investment vehicles – a continuous buffet of fees for the manager and promoter, Dixon Advisory Group (now Evans Dixon) and its associates. When we first read the fund’s financial statements we were amazed at the number of different fees Dixon and its associates (which we’ll refer to simply as ‘Dixon’) were able to charge to the fund. However, buried deep in the balance sheet or related party notes, we’d find yet another fee.

But it’s not just the fees that worry us about this fund. We have so many questions about the fund, its strategy, the strength of its balance sheet and the risks, that even if we were to ignore the fee load, we’d be unlikely to ever get comfortable making an investment.

The fund and its investment strategy

Launched in 2011, and listed on the ASX in 2012, the fund was initially presented as an opportunity for Australian investors, with the benefit of a strong Australian dollar, to invest in residential real estate in the New York metropolitan area (mainly Hudson County, New Jersey) at attractive valuations. Rental yields were expected to be greater than 8 per cent a year.

Over time the investment strategy has morphed into what is today, a strategy of buying and renovating properties in neighbourhoods undergoing rapid growth and gentrification, with the intention of ultimately leasing them. This has transformed the fund into less of a passive, rent earning investor and more of a property speculator, with a large proportion of the fund’s earnings coming from revaluations of the properties it owns (more below).

Property investors know that managing (and renovating) a property isn’t a simple or cheap exercise and this shines through in the portfolio owned by this fund. The fund requires a large range of services, with the key ones provided by Dixon. In addition to being the investment manager, Dixon provides the following paid services: the responsible entity; administration and accounting; architecture, design and construction; property management and leasing; property acquisition and disposal; execution, structuring and arranging (capital raisings); and debt arranging. Dixon also charges a handling fee when it raises new capital from its clients.

You won’t be surprised to learn this shopping list of services isn’t cheap. Details of some of the services and the fees charged can be found in the Services and Fees  section of the fund’s website. In Table 1, we’ve summarised these and the others we’ve found scattered throughout the financial statements and the Product Disclosure Statement (PDS).

We’ll return to the smorgasbord of fees in a moment. First let’s take a quick look at what the fund owns and where the money comes from.

The portfolio

Pictures of funky Brooklyn, Manhattan and Hoboken townhouses are scattered throughout the regular quarterly updates (click here for the 31 March 2016 update). However, it’s not what the properties look like, or where they’re located that’s of interest to us. We’re focused on whether they’re being leased or not.

Table 2 shows the fund’s portfolio at 31 March 2016, including both freestanding properties owned directly and multi-family buildings owned through various joint venture entities. The status of these properties is as follows:

Occupied (leased) – 63 per cent
Renovation/turnover – 34 per cent
For lease – 3 per cent

Due mainly to renovation works, effectively a third of the fund’s assets aren’t available for lease. Combined with rising valuations and falling rental yields, this means the days of the fund being a high yielding investment are gone, at least for now.

In the year ended 31 December 2012, the fund earned $4.2 million of rental income on an average investment property balance of $67 million. Given the rapidly growing nature of the fund it’s a very rough estimate, but this equates to an average rental yield of over 6 per cent. Revaluations of properties contributed another $5.7 million of profit (a little more than the rent).

Fast forward to 31 December 2015 and the (now much larger) fund earned almost $22 million of rental income on an average investment property balance around $703 million. That equates to an average yield just over 3 per cent. Meantime, property revaluations contributed almost twice as much as rent – about $40.8 million.

These figures highlight the increasingly speculative nature of the fund’s investment portfolio and also why the fund has struggled to generate positive operating cash flow since its inception. Even if the fund shifts to a position where the portfolio is fully (or almost fully) leased, this basic proposition is unlikely to change, at least anytime soon.

In the 31 March 2016 update Dixon estimated that the fund would earn another USD11.4 million in rent from the properties currently being renovated. While this might eliminate last year’s $14.4 million ‘core’ loss (see Table 4 and related discussion below) it would only reduce the negative $30.6 million operating cash flow, not turn the fund into a positive operating cash flow producer.

The fund has a low level of income, high level of expenses and relies on non-cash items to turn a profit. This, together with its growing acquisitions, means that it has had to continually tap unitholders on the shoulder for further capital and borrow from a variety of sources.

The current funding structure for the fund is set out in Table 3. A key feature is the two tranches of URF Notes that were issued in 2014 and 2015 and pay a fixed interest rate of 7.75 per cent.

The use of borrowing adds to the speculative nature of the fund’s portfolio. In the case of the URF Notes, often the fund is effectively borrowing money at 7.75 per cent to buy assets which won’t earn a cent initially, will have substantial sums spent renovating them and then will be put out to lease to earn rental income at a rate of say 3 to 4.5 per cent (although hopefully calculated on an upgraded book valuation).

Put this way, it’s fairly obvious why the fund’s strategy is such a cash drainer in the early years and how it could come unstuck. A downturn in the New Jersey or Brooklyn property markets (where most of the fund’s assets are located) could place pressure on both the ability to revalue the properties upwards (post renovation) and flat or falling rents. In this scenario the ability of the fund to pay its interest bill and generate a reasonable profit for unitholders, could be pushed a long way into the distant future.

Depending on the severity, a property downturn could cause the fund to have to sell properties in order to repay the URF Notes (which mature in 2019 and 2020) and other debts, exacerbating the fund’s problems in generating cash.

The early year cash flow drought associated with the underlying portfolio is magnified by the substantial levels of fees and other expenses incurred by the fund.

Let’s take a look at them in more detail.

Financial analysis

To put it bluntly, we’ve seen very few fee-fests like this fund. Perhaps some of the crazy tax deals beat it – for instance, managed agricultural schemes – but we struggle to recall a more traditional investment fund that’s paying fees in the order of five per cent or more (calculated as a percentage of the net asset base), year-in, year-out.

Admittedly, it’s not an apples for apples comparison to something like an Australian share fund, since property is typically a more expensive asset class to manage. But asset class alone doesn’t explain the continually high fee load being borne by this fund.

Table 4 shows the fund’s accounting results for each year since it was launched, and Table 5 shows some key financial ratios. We’ve used our own display format as it better demonstrates how the fund loses money on a ‘core’ basis each year, but generates a profit through renovating and revaluing the properties and, perhaps even more importantly, foreign exchange (FX) gains. It also highlights the amount of fees that have been paid by the fund since it was created.

At 31 December 2015, the fees totalled almost $100 million, and there’s a chance we’ve missed some as the fund’s disclosure of fees is both complicated and in a constant state of flux. If there’s an easily digestible summary of the fees paid by the fund somewhere on the Dixon website, we haven’t found it.

We’ve already discussed the fund’s low level of income and high levels of URF Note interest. When you add in the fees, it explains the large operating cash outflows the fund has experienced since launch. Cumulatively, the fund has burned through almost $50 million in operating cash flow between launch and 31 December 2015.

Fees on borrowed money

Dixon is paid an extraordinary array and volume of fees, but that’s not the only issue. Despite earning fees for managing and renovating the portfolio, making
purchases and sales and raising money, Dixon is paid an investment management fee of 1.24 per cent (for whatever aspect of the fund’s investment management that hasn’t been paid for already), together with administration (0.25 per cent), responsible entity (0.08 per cent) and custodian fees (0.02 per cent). Added together, these percentage fees add to 1.59 per cent, plus GST.

Scarily, these fees are paid on the gross assets of the fund, so it currently works out at around 3 per cent based on the unitholders equity (with all the transaction based fees on top). This is a massive fee load but even worse, the fact the fees are on gross assets gives Dixon a strong disincentive to deleverage the fund (at least, by diverting income or asset sale proceeds to paying down debt) since they’d effectively be costing themselves a substantial amount of money. A perverse incentive like this is the very reason we don’t like geared investment vehicles paying fees on gross assets.

So there you have it: the fund is an extraordinarily expensive cash burner. However, the fund has survived and prospered, largely on the back of three critical factors: property revaluations, foreign exchange gains and the ability to regularly source new capital and borrowings.


Table 4 demonstrates how the fund relies on property revaluations and foreign exchange gains to compensate for large ‘core’ losses. While the gains on  revaluations may ultimately be reflected in a higher level of rental income (or asset sale proceeds) the FX gains are ‘one-off’ profit items that may not be  repeated, or may even reverse themselves in future years.

Worryingly, through to 31 December 2015, FX gains on translation contributed almost 100 per cent of the cumulative post-tax accounting profits of the fund.
Effectively, for all of the fund’s activity and the substantial revaluation gains made as a result of renovations, the fund’s accounting profits to date have more to do with the recent depreciation of the AUD against the USD than anything property related.

In the 31 March 2016 update, Dixon reported that the fund has produced returns of 11.7 per cent a year since its launch in June 2011. However, over that same period, the US dollar itself has returned over 7 per cent a year (measured in AUD returns) and a simple US property , such as the Vanguard REIT (NYSE Code:  VNQ), has returned around 11.5 per cent.

In AUD terms, that works out at almost 20 per cent a year for a simple real estate , that doesn’t have the development risk or financing risk associated with URF. URF is a great example of reasonable absolute performance hiding terrible relative performance.


More worrying than the lacklustre performance is the amount of risk taken to achieve it. At first glance, a debt-to-equity ratio for a property trust of just under 50 per cent (at 31 March 2016) is nothing to get too worried about. But this fund is no ordinary property trust. It’s part property owner, part developer, part FX speculator (due to the fact it has issued the URF Notes in Australian dollars) and part guarantor of the juicy Dixon fee arrangements.

Without knowing whether Dixon intends to ease off the ‘buy and renovate’ strategy, repay the URF notes, or restructure some of the fee arrangements it’s difficult to tell when this fund may produce positive operating cash flow, or indeed whether it will ever do so. That means it’s relying on being able to raise further capital, borrow, or sell assets at a profit in order to pay the bills.

The problem with this type of approach is that everything can come unstuck at once. A downturn in the property market would make it difficult to sell assets
at a profit and tough to borrow or raise capital (except at a large valuation discount). In that scenario, the fund may be forced to sell assets at discounted
valuations to raise cash and if that happens the debt to equity ratio can increase rapidly.

If the fund had a property portfolio generating, say, a 5 per cent rental yield, with expenses running at 2 per cent a year, the story might be very different. In that case, it might be able to sit tight, pay its interest bills and wait for a recovery. However, the fund’s constant operating cash outflows means it has to continually tap unitholders and lenders for more cash and if that dries up, the conservative approach is to assume it will have big problems.

Summing it up

We could dig further into the property portfolio – for instance, analyse per square metre lease rates for Hoboken rental properties – but it really doesn’t matter. This fund has produced relatively little for investors versus alternative investments, largely because it suffers under a crushing fee and expense load that has eroded a lot of the gains produced by FX movements and a buoyant underlying property market.

Looking forward, with FX gains more difficult to come by, unitholders are taking on an enormous amount of risk since the fund is now substantially leveraged and has an expense load that keeps on increasing. It’s unclear exactly how a property downturn might play out, but our concern is that this fund could end up suffering a crunch and suffer massive losses from having to sell assets on the cheap.

If you know enough about New Jersey property to be bullish on freestanding Hoboken houses, buy one directly, or team up with some fellow investors to do so. But if you’re simply an Australian SMSF trustee looking for some exposure to global property and infrastructure, there are plenty of better options available. You simply don’t need this fund, or the expense and the risk that comes with it.

Disclaimer: This article is general in nature and does not take your personal situation into consideration. This article is not a recommendation of any investment or facility mentioned in it, and you should seek financial or legal advice specific to your situation before making any financial and/or investment decision. This  disclaimer is in addition to our standard Terms and Conditions. The Product Disclosure Statement (Offer Document) for this fund can be found here.

Are you looking for an advisor that will keep you up to date and provide guidance and tips like in this blog? Then why not contact me at our Castle Hill or Windsor office in Northwest Sydney to arrange a one on one consultation. Just click the Schedule Now button up on the left to find the appointment options.

Liam Shorte B.Bus SSA™ AFP

Financial Planner & SMSF Specialist Advisor™

SMSF Specialist Adviser 

 Follow SMSFCoach on Twitter Liam Shorte on Linkedin NextGen Wealth on Facebook   

Verante Financial Planning

Tel: 02 98941844, Mobile: 0413 936 299

PO Box 6002 BHBC, Baulkham Hills NSW 2153

5/15 Terminus St. Castle Hill NSW 2154

Corporate Authorised Representative of Viridian Select Pty Ltd ABN 41 621 447 345, AFSL 51572

This information has been prepared without taking account of your objectives, financial situation or needs. Because of this you should, before acting on this information, consider its appropriateness, having regard to your objectives, financial situation and needs. This website provides an overview or summary only and it should not be considered a comprehensive statement on any matter or relied upon as such.

Superannuation contribution changes for those nearing retirement

Government Proposal

The Morrison Government is taking action to help Australians boost their retirement savings by giving them greater flexibility as they near their retirement years. 

In a pre-budget announcement, the Treasurer, Josh Freydenberg has announced a number of proposed changes to superannuation contribution rules;

  1. From 1 July 2020 Individuals who are 65 to 66 will be able to contribute to their Superannuation without needing passing the 40 Hours in 30 days work test in the year of contribution. It has already been proposed that individuals over age 65, who have passed the work test in the previous financial year, would be able to contribute so this would seem to be a modification to that announcement. This will align the Work Test with the eligibility age for the Age Pension, which is scheduled to reach 67 from 1 July 2023. 
  2. The previous announcement will still be useful for those who retire aged 67-73.
  3. The spouse contribution age limit will be extended from 69 to 74. This allows a person to contribute up to $3000 to their spouse’s Superannuation and receive a tax offset of up to $540. Currently, those aged 70 years and over cannot receive contributions made by another person on their behalf.
  4. The 3 year non-concessional bring forward age limit will be extended from age 65 to 66. This could allow those who turned 65 and extra year of tax planning to put up to $300,000 in to their Superannuation. Valuable measure if you want to retire at 65 but not sell a CGT asset until the new tax year.

These are still proposals and nothing that the treasurer has proposed will proceed unless there is Opposition support or the current government pull off a surprise election win.   

If they do get passed I will write up some strategies especially for those looking to sell assets to boost super near retirement.

Liam Shorte


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