Hello Phuong
Thanks for the question.
Strictly speaking, as fund auditors, we are not being asked to form an opinion on whether the trustee of an SMSF has satisfied their TBAR reporting obligations.
A failure to lodge a TBAR in a timely manner (or indeed failure to lodge a TBAR at all) is not a breach of one of the seven trustee behaviour tests or one of the reportable SIS Act sections or SIS Regulations.
That said, TBARs might be viewed as documentation that supports the commencement, partial commutation or full commutation of a pension.  However, in the three instances just referred to (commencement, partial commutation or full commutation) there are better and more highly regarded forms of audit evidence.
So whilst as auditor you can certainly ask for a TBAR, and it may even be sensible to ask for a TBAR where a fund has had a reportable event – such as a fund member starting a pension – it is not absolutely necessary to ask for it.
Happy to hear the views of the other auditors on this matter.
Best regards
The Auditors Institute