Target Market Determinations

Design & Distribution Obligations

On 5 October 2021, the Design and Distribution Obligations (DDO) came into effect for all issuers and distributors of financial products that are required to meet the obligations. We are currently working through our obligations as an issuer and distributor, as well as how we are going to work with the distributors of our products to meet these new requirements.
As we work through these new requirements, we will update the information on this page so check back for more detail on our proposed approach.

Current TMDs

Accumulation Product TMD

Pension Product TMD


What are the Design and Distribution Obligations (DDO)?

DDO requires issuers and distributors of financial products to have a consumer-focused approach to the design and distribution of their products, aimed at helping consumers to obtain financial products that are appropriate for their objectives, financial situation and needs.

The obligations apply to a broad range of financial products including (but not limited to) investor directed portfolio services and superannuation products.

What is a Target Market Determination (TMD)?

A TMD is a document that details the target market for a financial product and matters relevant to the product’s distribution and review. As a product issuer it’s our responsibility to create a TMD for each of our products covered by DDO that:

  • Describes the Target Market: Outlines the likely objectives, financial situation and needs of customers the product has been designed for.
  • Establishes Distribution Conditions: Details the conditions or restrictions on the sale of the product.
  • Establishes Reporting Requirements: Sets out the relevant information that must be provided to us by distributors at our required frequency. At a minimum, a distributor must regularly report the number of complaints it receives about the issuer’s product to the issuer, as well as report any significant dealings in the product that are inconsistent with the TMD.

TMDs do not replace Product Disclosure Statements (PDSs) nor do they lessen the importance of PDSs in the financial product decision-making process. TMDs set out who the financial product may be suitable for and how it can be distributed. It is important to note that the TMD is not a summary of the product features, nor does it outline the terms of the product. The PDS should always be referred to for the terms, conditions and features of the product before deciding whether the product is suitable for the consumer.

Key Obligations

Key obligations for a product issuer

Our key responsibilities as a product issuer are to:

  • Create and maintain the TMD for all our products that are covered by DDO.
  • Take reasonable steps to ensure our products are distributed in line with those TMDs.
  • Review the TMDs to ensure they remain appropriate.

Key obligations for a product distributor

The key obligations for product distributors are to:

  • Ensure there is a TMD in place for all products that they distribute which are covered by DDO.
  • Understand and follow the distribution conditions and reporting requirements set by the product issuer in the relevant TMD.
  • Take reasonable steps to ensure the product is distributed in line with the TMD.
  • Keep records of distribution information.

We expect all distributors of AMG Super products to comply with these requirements.

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PO Box 3528, Tingalpa DC, QLD 4173

1300 264 264