We as a firm have been submitting transfer applications since the end of January 2019 when the transfer application facility went live on the RPA online, and we were surprised to see that several glitches that had caused problems in 2018 remained “unfixed” and were occurring again.
Each of the first transfers submitted were confirmed multiple times by the RPA online automatic confirmation of transfer message system, causing worry to transferors who feared that many more entitlements had been transferred out of their SBI than they should. Thankfully the “Transfer In and Out” screen only showed one transfer, however this was a glitch that occurred in 2018 which one would have hoped the IT team at the RPA could have prevented happening again. When we notified the RPA about this glitch, it resulted in a temporary suspension of the automatic confirmation of transfers (from the 6.2.19) to try and find a fix. The online confirmation of transfer message system was taken offline for over a fortnight, but eventually this issue was resolved and the messages (only one per transfer!) started coming through again.
We also noted that a number of transfers submitted early on were not confirmed automatically, despite the entitlements definitely being available to transfer, and the transferee having a valid registered business and SBI number. We were advised that the hold-up was due to the transferee not meeting the “active farmer” check that the computer was applying in error, either due to being a new entrant, or simply not having their 2018 claim yet processed. When we queried why this check had not been removed from the process (as of course there has been no active farmer requirement for transfers or even BPS claims since 2018) initially we were advised that the issue of “..transfers being blocked due to no active farmer declaration .. is due to be resolved with “Release1” which is currently scheduled for 12/2/19”. However although the Release 1 upgrade was applied to the back-end of the RPA online system, they did not remove the active farmer check which was holding up transfers. We were advised that “…the check will now be removed as part of Release 2 with an added upgrade in that once the active farmer check has been removed, those transfers which are currently being held by this error will automatically be approved. As yet we don’t have a confirmed date for Release 2 but on a positive note the stuck transfers won’t need any manual intervention as they will auto approve.”
At the time of writing the RPA has still not applied Release 2, and currently the RPA advises there is still no date for Release 2 to be applied. We suggested that the active farmer declaration could be made available online once again, so that transferees could tick this and transfers could then be “pushed through”, as happened in 2018. However there appears little appetite at the RPA for this solution, and they continue to work on trying to remove the glitch.
It is unsettling for both sellers and purchasers who are caught in this loophole, as agents transferring entitlements cannot release sale proceeds until the transfers are confirmed in writing by the RPA, and purchasers cannot be sure they have got the entitlements until they see them on their entitlements record. The fear is that, even though there is no need to be an active farmer to claim or receive entitlements, the status of the transferee as an active farmer will need to be confirmed to the RPA computer by a 2019 BPS claim being submitted, and as yet there has been no assurance that this will not be the case.