From: [ s.

22]
To: [ s.22]
Cc: [ s.22]
Subject: RE: MDBA water trade price audit [SEC=UNCLASSIFIED]
Date: Wednesday, 3 October 2018 6:09:22 PM
Attachments: image002.png
image003.png

Hi [ s.22] ,
Please refer [ s.22] response in red below.
Further, I’ll check with [ s.22] on item #5. Thanks
[ s.22]
Assurance Adviser
People, Capability and Transformation

Level 14, 169 Macquarie Street, PARRAMATTA, NSW, 2150

[ s.22]

PO BOX 398, PARRAMATTA, NSW, 2150

[ s.22] @waternsw.com.au
www.waternsw.com.au

From: [ s.22]
Sent: Thursday, 27 September 2018 1:52 PM
To: [ s.22]
Cc: [ s.22]
Subject: MDBA water trade price audit [SEC=UNCLASSIFIED]
Hi [ s.22]
While we are still looking at the supporting documents [ s.22] provided on allocation
trading in NSW, there are issues we would like to clarify before completing our testing ( some of
these of course are consistent with those identified from testing of supporting documents for
the processing of entitlement trade applications received). Please feel free to comment and/or
provide additional information as considered necessary:
1. The application form only identifies that it is mandatory to enter a sale price in per ML, not
that the need to enter a price is mandatory. Has any consideration been given to
identifying this as a compulsory field where the seller has the obligation to accurately
report price under s12.48 of the Basin Plan? Are you saying that the language is not
necessarily reflective of s12.48? We can consider adjusting this to clarify requirements as
per s12.48
2. Applicants are not required to provide any evidence of the price that was agreed between the
buyer and seller. Do the team processing allocation trade applications have any internal
processes for forming a view on the market value of prices reported? Do they make any
enquiries to confirm the non commercial status of zero prices reported? Given the
variety of types of assignment arrangements, there is an expectation that prices will vary
from $0 (e.g. move between same owner’s licences) to current market rates. It is
impractical under the current process to manage the compliance of prices reported.
s12.48 does not state anything around compliance by us, only an obligation by the
parties of the deal to report the price.
3. [ s.22]
 [ s.22]

4. In your e-mail last Thursday, you reconfirmed that the water assignment checklist is only
completed where an application fails to comply with your requirements and a copy is
provided to the applicant to advise of the action required. Can you please provide
clarification as to why an assessment summary checklist is not considered necessary
when one is completed for entitlement trade applications received? What is your line of
thought regarding this question?
5. Price agreed on the transfer of a water allocation is not captured in e-mail sent when approval
of an application is notified. Can we assume that response Monday on approval of
entitlement trade applications also applies to the e-mails sent on approval of an
allocation trade application? – I think this might be a question for Permanent Trades
[ s.22] team).
[ s.22]

[ s.22]

It would be appreciated if you could provide a response to this e-mail by COB Tuesday 2 October
2018. In the interim however, please do not hesitate to call if you need any clarification on the
issues raised.
Thanks
[ s.22]
Policy & Compliance Officer – Policy & Planning
Audit & Investigations
Murray-Darling Basin Authority
[ s.22]
[ s.22]
[ s.22] @mdba.gov.au
www.mdba.gov.au “

From: [ s.22] @waternsw.com.au]

Sent: Tuesday, 18 September 2018 2:46 PM
To: [ s.22] @mdba.gov.au>
Cc: [ s.22] @mdba.gov.au>
Subject: FW: ACTION REQUIRED - FW: MDBA Request: Water Trade Price Reporting sample
[SEC=UNCLASSIFIED]
Hi [ s.22] ,
Apologies for the lengthy delay in approval. Please find attached a zip file containing evidence as
outlined in your request below.
a. A copy of completed each ‘application form’ received – COMPLETE
b. Copies of completed Water assignment checklist The checklist is used to verify
information for each trade, with a copy being supplied back to the applicant only in the
event of a identified error.
c. Copies of ‘payment receipt’ for the application fee e.g. tax invoice, payway payment
receipt - COMPLETE
d. Notification of assignment finalisation to the applicant. - COMPLETE
e. Hydrogeologist assessment and approval (where the transaction is related to ground
water). – NO GROUNDWATER TRADES IN SAMPLE
f. Evidence of approval received from security holders where they have security interest
over an entitlement. I haven’t seen this before – do you mean like bank mortgage?
Closest we have is when licence is leased it shows in WLS as having a Term Transfer. I
spot check these daily.
g. Where the applicant is not the licence holder (evidence of any checks completed to
ensure that that applicant has the right to act on the licence holder behalf). Each
application form must have the box ticked authorising the submission of the trade by
the applicant. Unless identified for further investigation, this is sufficient for us to action
the trade as covered by other legislation relating to fraud.
If you have any further questions, please don’t hesitate to contact me.
Regards,
[ s.22]
Customer Contact Centre Team Leader
– Dubbo & Deniliquin

7 Commercial Avenue
Dubbo NSW 2830
[
[ s.22] @waternsw.com.au
www.waternsw.com.au

From: [ s.22] @mdba.gov.au>

Sent: Wednesday, 22 August 2018 9:15 AM
To: [ s.22] @waternsw.com.au>
Cc: [ s.22] @mdba.gov.au>; [ s.22]
<[ s.22] @waternsw.com.au>
Subject: MDBA Request: Water Trade Price Reporting sample [SEC=UNCLASSIFIED]
Hi [ s.22] ,
After completing our review of processes for the collection, recording and reporting of water
trade information, we are now moving on to the testing phase of the audit. This will involve a
review of key controls identified for fifteen of the applications received in 2017/18 (15 including
allocation and entitlements).
Please find attached a spreadsheet which identifies the transactions selected at random for
testing (relevant to allocations). For each of these, if we could please request the following
supporting documentation:
a. A copy of completed each ‘application form’ received
b. Copies of completed Water assignment checklist
c. Copies of ‘payment receipt’ for the application fee e.g. tax invoice, payway payment
receipt
d. Notification of assignment finalisation to the applicant.
e. Hydrogeologist assessment and approval (where the transaction is related to ground
water).
f. Evidence of approval received from security holders where they have security interest
over an entitlement.
g. Where the applicant is not the licence holder (evidence of any checks completed to
ensure that that applicant has the right to act on the licence holder behalf).
If we could please request that the above supporting documentation by COB Friday 24 August
2018 and that you use the sample number within the spreadsheet to reference the documents
to enable us to easily identify the supporting documentation it would be greatly appreciated.
In the interim, please do not hesitate to call if you want to discuss this request in any more
detail.
Thanks
[ s.22]
Assistant Director, Audit and Investigations

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