Design and Distribution Obligations

The design and distribution obligations (DDO) are intended to help consumers obtain appropriate financial products by requiring issuers and distributors to apply a consumer-centric approach to the design and distribution of their financial products.

To ensure that the distribution of its products is directed towards an appropriate target market, Australian Fiduciaries Limited has issued target market determinations (TMDs) for each class of units issued by its funds.

Target Market Determinations (TMDs)

Below are the TMDs issued by Australian Fiduciaries Limited for each class of units available for its funds. The TMD’s set out the who each class of units is appropriate for and any restrictions relating to the sale and distribution of the units.

Each TMD has separate distribution conditions in relation to the distribution of the units. Distributors are required to observe the relevant conditions for each unit class.

GSRI Ethical Alpha Fund ‘Conservative Units’ Target Market Determination – 20 December 2022.

GSRI Ethical Alpha Fund ‘Balanced Units’ Target Market Determination – 20 December 2022.

GSRI Ethical Alpha Fund ‘Growth Units’ Target Market Determination – 20 December 2022.

GSRI Ethical Alpha Fund ‘High Growth Units’ Target Market Determination – 20 December 2022.

GSRI Multi-Strategy Fund ‘Conservative Units’ Target Market Determination – 20 December 2022.

GSRI Multi-Strategy Fund ‘Balanced Units’ Target Market Determination – 20 December 2022.

GSRI Multi-Strategy Fund ‘Growth Units’ Target Market Determination – 20 December 2022.

GSRI Multi-Strategy Fund ‘High Growth Units’ Target Market Determination – 20 December 2022.

GSRI All Seasons Fund ‘Diversified Units’ Target Market Determination – 20 December 2022.

Reporting requirements for distributors

The following section is for distributors of Australian Fiduciaries Limited products and sets out Australian Fiduciaries Limited’s expected reporting requirements. Distributors include Australian Fiduciaries Limited’s related entities and authorised third party Australian financial services licensees.

Distributors must report to Australian Fiduciaries Limited using the following email address: admin@australianfiduciaries.com.au.

Distributors should adopt the FSC data standards for all reports.

Reporting requirement

Reporting period

Which distributors this requirement applies to

Complaints (as defined in section 994A(1) of the Act) relating to the product design, product availability and distribution.

The distributor should provide all the content of the complaint, having regard to privacy.

Within 10 business days following end of calendar quarter.

All distributors who have received a complaint in the relevant quarter

‘Significant Dealing’ outside of target market, under s994F(6) of the Act.

See ‘Significant dealings’ for further detail.

As soon as practicable but no later than 10 business days after distributor becomes aware of the Significant Dealing.

All distributors

To the extent a distributor is aware of dealings outside the target market these should be reported to the issuer, including reason why acquisition is outside of target market, and whether acquisition occurred under personal advice.

Within 10 business days following end of calendar quarter.

All distributors

 

Significant dealings

This guidance applies to all TMDs issued by Australian Fiduciaries Limited on this website.

Dealings may be ‘significant’ because:

  • they represent a material proportion of the overall distribution conduct carried out by the distributor in relation to the product, or
  • they constitute an individual transaction which has resulted in, or will or is likely to result in, significant detriment to the consumer (or class of consumer).

In each case, the distributor should have regard to:

  • the nature and risk profile of the product (which may be indicated by the product’s risk rating or withdrawal timeframes),
  • the actual or potential harm to a consumer (which may be indicated by the value of the consumer’s investment, their intended product use or their ability to bear loss), and
  • the nature and extent of the inconsistency of distribution with the TMD (which may be indicated by the number of red or amber ratings attributed to the consumer).

Objectively, a distributor may consider a dealing (or group of dealings) outside the TMD to be significant if:

  • it constitutes more than half of the distributor’s total retail product distribution conduct in relation to the product over the reporting period,
  • the consumer’s intended product use is Solution / Standalone, or
  • the consumer’s intended product use is Core component and the consumer’s risk (ability to bear loss) and return profile is Low.