Between 2014 and late 2024, the typical approach to determining whether an SMSF qualified as a wholesale investor was based on whether one or more of the trustees, as controlling parties, met either the net asset test ($2.5m) or the income test (earning $250,000 for two consecutive years).
Updated guidance from the Australian Financial Complaints Authority (AFCA) has said:
"where the financial service relates to a superannuation product, a trustee of an SMSF is classified as a retail client unless the fund holds net assets of at least $10 million at the time the service is provided (‘net assets’ test)."
And also:
"AFCA will continue to consider any service provided to an SMSF trustee pertaining to a superannuation fund as one involving a retail client unless the individual in question can satisfy the $10 million asset threshold for wholesale investors."
This means that even if one or more of the SMSF's members or trustees meets the wholesale investor test, the SMSF, as a superannuation fund, does not automatically meet the wholesale test.
Grow SMSF will not issue or sign any wholesale investor certificates for SMSF customers unless the fund has more than $10m in net assets.
Grow SMSF will not issue or sign any wholesale investor certificate for individual investors because we don't provide taxation services to individuals.