Wednesday we published our initial take on the LRBA abolition. Since then, the bill has passed both houses and is awaiting Royal Assent — expected imminently. We've now read the actual legislation, and there are two things you need to know: the transitional protection is more generous than the Greens' media release suggested, and the lender market is already contracting faster than the legislation.

What the Bill Actually Says About Protection

The Greens' media release said contracts signed before commencement would be protected. The actual bill text goes further. Schedule 5, Item 2(b) and the accompanying note state:

Direct from the bill — Schedule 5, Item 2, Note (c):

"a borrowing arrangement for which the related asset is acquired under an arrangement entered into before that commencement (even if the settlement for the acquisition of the asset happens after that commencement)"

In plain English: if you have a signed purchase contract before commencement, you are protected. Settlement can happen after the 45-day window closes. The LRBA can be established to fund that settlement even after commencement; because it's the acquisition arrangement (your purchase contract) that triggers the protection, not the borrowing arrangement itself.

This is meaningfully better than the initial read. The race is now to get a contract exchanged before Royal Assent + 45 days. Settlement timing is not the constraint.

The Commencement Date — Confirmed

The 45-day window is confirmed in the commencement table of the bill. Schedule 5 commences on the 45th day after Royal Assent. With the bill having passed both houses and Royal Assent expected within days, the clock will start very soon.

We are monitoring legislation.gov.au daily and will update clients the moment Royal Assent is confirmed and the precise deadline is known.

The Bigger Problem: Lenders Are Already Leaving

The legislative window may be 45 days, but the lender market is contracting right now; before the law has even commenced. AMP Bank announced today that it is pausing new SMSF residential loan purchase applications, effective immediately.

AMP Bank announcement — 25 June 2026:

"From 25 June 2026, we're pausing new SMSF SuperEdge residential loan purchase applications, including pre-approvals, following recent Government announcements."

"If you have an application in progress the loan must settle by 31 July 2026. This means you must have conditional approval by 30 June 2026."

AMP's exit matters because SMSF residential lending was already a thin market. Unlike standard residential lending where dozens of lenders compete, SMSF LRBAs were serviced by a small number of specialist lenders; primarily the major banks and a handful of non-bank lenders. Each exit doesn't just reduce competition, it removes capacity from an already constrained pool.

AMP will not be the last. As other lenders assess their risk exposure to a product that is being legislatively wound down, expect further announcements in the coming days and weeks. A lender with open SMSF applications has real pipeline risk; why accept new applications when settlements may become legally uncertain or commercially unviable?

What This Means Practically

The Dual Clock Problem

What's emerging is a dual deadline problem that's more complex than just the 45-day legislative window:

• The legislative deadline requires a signed contract before Royal Assent + 45 days.
• The lender deadline is being set independently by each lender as they exit; and AMP's deadline of 30 June for conditional approval is already inside the legislative window.
• Lender processing times haven't shortened; formal valuations, credit assessment, and loan documentation still take 2-3 weeks minimum, and that's before legal advice on loan documents which is mandatory for SMSF borrowing.
• A signed contract with no lender prepared to fund it doesn't get you anywhere; the protection is theoretical if the finance can't be arranged in time.

The practical implication: the effective window is not 45 days. It is however long the remaining lenders stay open, which is shorter and less predictable.

If You Are Currently Searching for a Property

This applies to you — call us this week

If you have an SMSF with funds ready and have been searching for a property to purchase via LRBA, the situation has changed materially since yesterday.

The lender pool is contracting in real time. The legislative protection requires a contract, not a settlement. The window to act is weeks.

We need to understand which lenders are still active, confirm your fund's borrowing capacity under current lender criteria, and ensure any property you move on can be financed within the available window.

This is not a 'monitor and review' situation. Please contact us this week.

The Bottom Line

The legislation is more generous than first reported; a signed contract is sufficient protection, and settlement can occur after commencement. That's genuinely good news.

The lender market is moving faster than the legislation. AMP has already gone. The practical window to act is determined by how long the remaining lenders stay open, which is now the binding constraint, not the 45-day legislative deadline.

If this affects you, the time to move is now.

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